Barejo Holdings ULC v. Canada, 2020 FCA 47 -- summary under Paragraph 94.1(1)(a)
the amount payable under a “debt” for s. 94.1(1)(a) purposes need not be crystallized until maturity
An offshore fund ("SLT"), in which the taxpayer had an interest, invested in instruments (labelled as "Notes") of non-resident subsidiaries of...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Consistency | presumption of consistent expression is not absolute | 252 |
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract | 3 tests for what constituted debt under s. 94.1(1)(a) | 300 |
| Tax Topics - Statutory Interpretation - Redundancy/ reading in words/ speaking in vain | presumption that Parliament was not speaking in vain | 54 |