See Also
Pièces automobiles Lecavalier Inc. v. The Queen, 2014 DTC 1126, 2013 TCC 310
Prior to its acquisition by an arm’s length purchaser, the Canadian taxpayer used share subscription proceeds from its US parent to pay a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Evidence | Canadian tax accountant's testimony on US tax consequences accorded little weight | 152 |
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) | debt-paydown transactions were avoidance transactions | 268 |
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | avoidance of debt forgiveness rules was abusive | 277 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(10) | debt-paydown transactions effected in contemplation of sale transaction were part of same series as the sales transactions | 248 |
Corner Brook Pulp and Paper Limited (Formerly Deer Lake Power Company Limited) v. The Queen, 2006 DTC 2329, 2006 TCC 70
In determining the fair market value of shares issues by a subsidiary ("Deerlake Power"), a power company, to its parent in satisfaction of debt...
King Rentals Ltd. v. The Queen, 96 DTC 1132, [1995] 2 CTC 2612 (TCC)
The pre-1994 version of s. 80 did not apply to the satisfaction of indebtedness of the taxpayer (a New Brunswick corporation) through the issuance...
Administrative Policy
10 March 1999 External T.I. 9829125 - PRICE ADJUSTMENT CLAUSE & 80(2)(G)
Although a price adjustment clause may be used for satisfying the requirements of s. 80(2)(g), "an acceptable price adjustment clause should not...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Effective Date | 36 |