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Under s. 247(2)(a), the Minister must determine whether those who were responsible for the separate existence of the corporations had, as their...

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After first finding that because the taxpayers' evidence was credible, there was no requirement for corroboration by external facts, Simpson J....

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Cullen, J. rejected the appellant's argument "that the language employed in subsection 247(2) ... is so vague and uncertain, and so subject to...

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"[T]he Minister, before issuing a direction under subsection [247(2)], must examine the reasons for the separate existence of the corporations in...

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The two subparagraphs of subsection 247(2) require the Minister to make what is in substance one determination, and a direction of the Minister...

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