Words and Phrases - "in contemplation of"

a
82
b
44
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75
d
50
e
37
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31
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17
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13
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71
j
2
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2
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30
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51
n
25
o
38
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79
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73
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85
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44
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20
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1

3295036 Canada Inc. v. Agence du revenu du Québec, 2018 QCCQ 8100, aff'd 2020 QCCA 1435

Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(10)
the use, years later, of stepped up ACB through sales of the property was “in contemplation” of the basis step-up series

On two days in October 1996, the parent company (“Marjad”) of the taxpayer (“3295036”) transferred shares of two public companies, whose...

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Words and Phrases
en vue de in contemplation of

Copthorne Holdings Ltd. v. Canada, 2012 DTC 5006 [at 6536], 2011 SCC 63, [2011] 3 S.C.R. 721

Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(10)
"in contemplation" could be retrospective

The taxpayer's shareholders circumvented the rule in s. 87(3), which required that the paid-up capital ("PUC") of a subsidiary corporation...

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Words and Phrases
in contemplation of
Locations of other summaries Wordcount
Tax Topics - General Concepts - Stare Decisis high threshold for reversing not met 193
Tax Topics - Income Tax Act - Section 245 - Subsection 245(1) - Tax Benefit tax benefit illuminated by comparison to reasonable and simpler alternative 425
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) policy of s. 87(3) is to avoid preservation of PUC on parent and sub amalgamation 372
Tax Topics - Statutory Interpretation - Expressio Unius est Exclusio Alterius implied exclusion principle 109