Atlantic Packaging Products Ltd. v. Canada, 2020 FCA 75 -- summary under Section 54.2

Summary Under
Tax Topics - Income Tax Act - Section 54.2
transfer of assets representing 68% of the FMV of the assets of a business division did not satisfy the “substantially all” test

The taxpayer, a paper products manufacturer, engaged in a hybrid transaction in which it sold some of the assets of its “Tissue Division”...

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Words and Phrases
substantially all
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Machinery and Equipment the number and frequency of similar dispositions of depreciable property was relevant to capital account treatment 341
Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Act - Section 27 - Subsection 27(1.3) raising of new issue would prejudice the Crown 222