Gillen v. The Queen, 2017 TCC 163, aff'd 2019 FCA 62 -- summary under Subparagraph 110.6(14)(f)(ii)
property was not used in a business for s. 110.6(14)(f)(ii) purposes when it was beneficially acquired and dropped-down on the same day
A corporation (“Kinderock”) owned by the taxpayer and his wife applied, commencing on October 4, 2007, to the Saskatchewan government for...
Words and Phrases
use| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Ownership | test of beneficial ownership | 112 |
| Tax Topics - General Concepts - Effective Date | relation-back theory applied: closing retroactively confirmed previous beneficial ownership transfer | 255 |