Mac's Convenience Stores Inc. v. A.G. of Canada, 2015 QCCA 837

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Summaries

Summary Under

thin cap issues were not considered at time of paying a dividend

The appellant, which was a wholly-owned Ontario subsidiary of a Quebec corporation ("CTI"), paid a $136 million dividend to CTI in connection with...

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Summary Under

dividend triggered application of thin cap rules

The taxpayer did not realize at the time that paying a substantial dividend to its Canadian parent (which reduced its retained earnings) would...

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