Magren Holdings Ltd. v. The Queen, 2021 TCC 42, aff'd on other grounds 2024 FCA 202 -- summary under Ownership
Summary Under
Tax Topics - General Concepts - Ownershipacquisition of income fund units to be held for a few days before their redemption did not represent an acquisition of beneficial ownership
The appellants, were private companies controlled by a resident individual (Grenon), whose RRSP held 58% of the units of a publicly traded income...
Words and Phrases
beneficial ownership| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 185 - Subsection 185(3) | Part III tax assessments of distributions of gains that were denied outside the Part I tax normal reassessment period were not statute-barred | 314 |
| Tax Topics - Income Tax Act - Section 185 - Subsection 185(1) | no requirement to issue separate assessment for each election, and no remedy for inordinate time to issue assessments | 396 |
| Tax Topics - General Concepts - Sham | transactions did not result in real capital losses | 306 |
| Tax Topics - Income Tax Act - Section 184 - Subsection 184(3) | election was not available where a CDA sham | 365 |
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | no CDA addition where capital gains were not real | 373 |