Words and Phrases - "winding-up"

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Michael Kandev, Olivia Khazam, "Was there a ‘Liquidation and Dissolution’? A (Corporate) Existential Question", International Tax (Wolters Kluwer CCH), No. 118, June 2021, pp. 8-9

Commercial understanding of “liquidation” and “dissolution” (p. 8)

I]t is reasonably clear that the terms "liquidation" and "dissolution"...

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Ian Bradley, Jonathan Bright, "The Stop-Loss Rules and Corporate Reorganizations – Interpretive Challenges", Canadian Tax Journal, (2019) 67:2, 383-410

Interpretation of "merger or combination" (pp. 391, 394, 396)

The CRA's interpretation of subparagraph 40(3.5)(c)(i) [in 2017-073715117] is based...

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Words and Phrases
merger combination winding-up

Dauphin Plains Credit Union Ltd. v. Xyloid Industries Ltd., 80 DTC 6123, [1980] CTC 247, [1980] 1 S.C.R. 1182

"liquidation" includes forced (and not just voluntary) distribution of all the assets of a company

The appellant was a secured debentureholder who, following default by the debtor (“Xyloid”), obtained a court order for the appointment of a...

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Words and Phrases
liquidation winding-up

Kvas v. The Queen, 2016 TCC 199

involuntary dissolution was not a s. 84(2) winding-up

The general contracting company (“CIA”) of two brothers was dissolved in January of 2008 (the “Dissolution Date”) for failure to file...

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Words and Phrases
winding-up
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 160 - Subsection 160(1) involuntary dissolution did not render the corporation a transferor 195

Merritt v. MNR (1941), 2 DTC 513 (Ex Ct), rev'd [1942] S.C.R. 269, 2 DTC 561

The Premier Trust Company ("Premier") acquired all the shares of the taxpayer and other shareholders of the Security Loan and Savings Company...

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Words and Phrases
winding-up

Gilmour v. The Queen, 81 DTC 5322, [1981] CTC 401 (FCTD)

The taxpayer was the sole individual shareholder of a personal corporation ("LVG") which, in turn, owned approximately 1/3 of the common shares of...

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Words and Phrases
winding-up

Perrault v. The Queen, 78 DTC 6272, [1978] CTC 395 (FCA)

business continued "on a reduced scale"

A substantial dividend was not paid on the "winding-up, discontinuance or reorganization" of a company's business because, following the payment...

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Words and Phrases
winding-up

Smythe et al. v. Minister of National Revenue, 69 DTC 5361, [1969] CTC 558, [1970] S.C.R. 64

application to de facto winding-up and discontinuance

The taxpayers were shareholders of a company (the "old company") who effectively converted its assets to cash through a series of transactions:...

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Words and Phrases
winding-up