Words and Phrases - "group of persons"

a
82
b
44
c
75
d
50
e
37
f
31
g
17
h
13
i
71
j
2
k
2
l
30
m
51
n
25
o
38
p
79
q
2
r
73
s
85
t
44
u
14
v
8
w
20
y
2
“
1

Madison Pacific Properties Inc. v. The King, 2023 TCC 180

Summary Under
Tax Topics - Income Tax Act - Section 111 - Subsection 111(4)
two acquirers of most of the equity of a Lossco were acting in concert so as to constitute a group

The appellant (“MPP”) was an insolvent, publicly traded, mining company with accumulated non-capital and net capital losses of $9.7 million...

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Words and Phrases
group of persons
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) acquisition of close to legal control of a Lossco by two arm’s length companies in a different business to access its losses was an abuse 452
Tax Topics - Income Tax Act - Section 245 - Subsection 245(1) - Tax Benefit in the alternative transaction, two acquirers of the shares of a Lossco would have been acting in concert so as to be a group that acquired control of the Lossco 291

Promutuel Réassurance v. The Queen, 2020 TCC 13

Summary Under
Tax Topics - Income Tax Act - Section 256 - Subsection 256(7) - Paragraph 256(7)(d)
27 insurance companies who acted in a cooperative manner were a “group of persons” for s. 256(7)(d) purposes

The taxpayer (“ProRé”) was a corporation without share capital engaged in the reinsurance of casualty risk whose capital had been contributed...

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Words and Phrases
group of persons
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 256 - Subsection 256(8.1) s. 256(8.1) deemed non-share insurance corporation to have issued shares to its insurance-company members 154

Yardley Plastics of Canada Ltd. v. MNR, 66 DTC 5183, [1966] CTC 215 (Ex Ct)

Summary Under
Tax Topics - Income Tax Act - Section 256 - Subsection 256(1) - Paragraph 256(1)(b)

Two corporations whose voting shares were held as follows

Shareholder Canadian Moldings Yardley Plastics
Hill 4.6% 28%
Hill...

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Words and Phrases
group of persons

Vina-Rug (Canada) Limited v. Minister of National Revenue, 68 DTC 5021, [1968] CTC 1, [1968] S.C.R. 193

Summary Under
Tax Topics - Income Tax Act - Section 256 - Subsection 256(1) - Paragraph 256(1)(b)

Because John Stradwick, Jr., his brother W.L. Stradwick and H.D. McGilvery, who collectively owned more than 50% of the shares of Stradwick's and...

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Words and Phrases
group of persons group

Birchcliff Energy Ltd. v. The Queen, 2015 TCC 232, nullified on procedural grounds 2017 FCA 89

Summary Under
Tax Topics - Income Tax Act - Section 111 - Subsection 111(5) - Paragraph 111(5)(a)
grant of proxy did not detract from investors acting individually in own interest

A predecessor ("Birchcliff") of the taxpayer negotiated a plan to merge with a corporation ("Veracel"), which had discontinued its medical...

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Words and Phrases
group of persons
Locations of other summaries Wordcount
Tax Topics - General Concepts - Sham transitory share issuance under plan of arrangement was not a sham 177
Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) share subscription was avoidance transaction notwithstanding its "overarching purpose" was financing 148
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) abusive reverse takeover by Lossco through diverted private placement 261