Ludco Enterprises Ltd. v. Canada, 2001 DTC 5505, [2001] 2 S.C.R. 1082, 2001 SCC 62 -- summary under Subparagraph 20(1)(c)(i)

ancillary purpose of earning (1%-yield) dividend income/allocation of reinvested proceeds 100% to income-producing source

A group of Canadian investors, including the taxpayers, invested in the shares of two Panamanian corporations (collectively, "Justinian") whose...

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Words and Phrases
income
Locations of other summaries Wordcount
Tax Topics - General Concepts - Purpose/Intention objective and subjective manifestations of purpose 104
Tax Topics - General Concepts - Tax Avoidance right to structure for tax avoidance 129
Tax Topics - Statutory Interpretation - Certainty inferring of subjective test is contrary to the objective of certainty 103