Cases
Meredith v. Canada (Attorney General), 2002 DTC 7190, 2002 FCA 258
The trial judge had lifted the corporate veil by treating the taxpayer and a corporation of which the taxpayer was the sole shareholder and...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 122.3 - Subsection 122.3(1) | 40 |
See Also
Fourney v. The Queen, 2012 DTC 1019 [at 2575], 2011 TCC 520
Seeking to protect herself from being sued by her brother, the taxpayer transferred title to all her real properties for no consideration to...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Agency | 191 | |
| Tax Topics - General Concepts - Ownership | presumption of resulting trust where property transfer for no consideration | 257 |
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(1) | bare trust arising on creditor-proofing transfer | 257 |
| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | line codes in electronic filings were incomprehensible to taxpayer | 300 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | rebuttable presumption of resulting trust on transfer for no consideration | 257 |
Martel v. The Queen, 2003 DTC 1187 (TCC)
In rejecting a submission that, in determining whether a corporation was carrying on an active business, account could be taken of the activities...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation | 134 | |
| Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) | 134 |
K.J. Beamish Construction Co. Ltd. v. MNR, 90 DTC 1584, [1990] 2 CTC 2199 (TCC)
The taxpayer, which was a shareholder of a private corporation engaged in land development and to which it made advances, was unable to deduct...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Personality | 119 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss | 54 |
Articles
Perry, "Capitalization and Asset Acquisitions for New Private Corporations", 1993 Conference Report, C. 22
Discussion (at pp. 7-11) of the corporate veil.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Personality | 8 |
separate existence
See Also
Barnwell v. The Queen, 2015 DTC 1115 [at 724], 2015 TCC 98 (Informal Procedure), aff'd 2016 FCA 150
Before finding that a loan made by the taxpayer to an individual, who was the sole director and shareholder of a business corporation...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(c) | loan made to the principal of a business corporation could not be construed as a corporate loan | 79 |