Canada v. Canadian Pacific Ltd., 2002 DTC 6742, [2002] 3 F.C. 170, 2002 FCA 98 -- summary under Transaction
an aspect of a transaction is not a transaction
The Crown argued that CP's act of denominating the debentures in Australian dollars was in and of itself a transaction and that it amounted to an...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) | primary purpose of a borrowing in a tax-advantageous currency was to raise money | 290 |
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | transaction not to be recharacterized until after a determination of abuse | 283 |