Aeronautic Development Corporation v. Canada, 2018 FCA 67 -- summary under Subsection 256(5.1)
non-resident exercised de facto control of mooted CCPC under a development agreement
The taxpayer (“ADC”) was denied refundable SR&ED investment tax credits on the basis that a U.S. resident (Mr. Silva) and a U.S. corporation...
Words and Phrases
supply contract| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) | sole customer under single contract dominated the company | 317 |