Submitted by narmstrong on Wed, 08/31/2022 - 03:00
pipeline transactions of an alter ego trust implemented over an extended period
Background
Before his death, Father transferred his shares (i.e., 50.5% of the common shares) of ACo (which held a diverse portfolio of bonds,...
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Principal Issues: 1) Whether section 84.1 applies to deem the alter ego trust to have received a dividend on the disposition of shares to the new corporation. 2) Whether subsection 84(2) applies to the proposed transactions. 3) Whether subsection 245(2) applies to the proposed transactions.
Principal Issues: Is the income earned by an individual, who identifies as a member of the Moorish Americans, exempt from tax?
Position: No.
Reasons: Paragraph 81(1)(a) of the Income Tax Act and section 87 of the Indian Act provide an income tax exemption for individuals who are registered or entitled to registered under the Indian Act and whose income is situated on a reserve.
