AgraCity Ltd. v. The Queen, docket 2014-1537

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Summaries

Summary Under

Reply must explain specific bases on which a penalty was imposed

The taxpayer purportedly arranged to have most of the profits arising from sales of a product earned by a Barbados company. The Minister assessed...

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Summary Under

factual allegation that foreign affiliate did nothing was fatal to ss. 247(2)(a) and (c) pleadings but not ss. 247(2)(b) and (d)

In her Reply, the Minister alleged that a Barbados corporation ("NewAgco") which did not deal at arm's length with the taxpayer, took over a...

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Summary Under

argument inconsistent with assumed facts struck from pleadings, but might be reintroduced at trial as an alternative argument

In her Reply, the Minister alleged that a Barbados corporation ("NewAgco") which did not deal at arm's length with the taxpayer, took over a...

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