Words and Phrases - "series of transactions"

82
43
75
50
36
31
17
13
71
2
2
30
51
25
38
79
2
73
85
44
14
8
20
2
1

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
series of transactions
Locations of other summaries Wordcount
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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
series of transactions
Locations of other summaries Wordcount
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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
series of transactions

OSFC 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)...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
series of transactions
Locations of other summaries Wordcount
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