Words and Phrases - "series of transactions"
Cameco Corporation v. The Queen, 2018 TCC 195, aff'd 2020 FCA 112
"series" concept narrowly interpreted to permit comparison with arm's length transactions
Owen J found (at para. 704) that the concept of a “series” under s. 247(2) should be interpreted narrowly in order to not make it impossible...
Words and Phrases
series of transactionsLocations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) | having a Swiss/Lux subsidiary enter into long-term purchase contracts at a somewhat fixed price with third parties and the taxpayer did not engage s. 247(2) | 708 |
Tax Topics - General Concepts - Sham | transactions that were not factually misrepresented were not a sham | 254 |
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(1) - Transaction | meaning of "arrangement" and "event" | 153 |
Craven v. White, [1988] BTC 268 (HL)
a series if no real likelihood that the successive transactions will not occur
Lord Jauncey stated:
"If it were appropriate to prepare a formula defining 'composite transaction' in the light of the passages in the speeches in...
Words and Phrases
series of transactionsLocations of other summaries | Wordcount | |
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Tax Topics - General Concepts - Tax Avoidance | 203 |
Lipson v. Canada, 2007 DTC 5172, 2007 FCA 113, aff'd 2009 DTC 5015 [at 5528], 2009 SCC 1
The taxpayer's wife ("Jordanna") borrowed $562,500 from the Bank of Montreal under an interest-bearing demand promissory note in order to purchase...
Words and Phrases
series of transactionsOSFC Holdings Ltd. v. Canada, 2001 DTC 5471, 2001 FCA 260
Although the "common law" meaning of a series of transactions was transactions each of which is pre-ordained to produce a final result, s. 248(10)...
Words and Phrases
series of transactionsLocations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) | significant disparity between tax benefit and commercial return from transaction | 263 |
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | policy against corporate loss trading | 229 |
Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc. | 70 | |
Tax Topics - Statutory Interpretation - Interpretation/Definition Provisions | deeming v. definition provisions | 46 |