Canada v. Deans Knight Income Corporation, 2021 FCA 160, aff'd 2023 SCC 16 -- summary under Paragraph 111(5)(a)

Summary Under
Tax Topics - Income Tax Act - Section 111 - Subsection 111(5) - Paragraph 111(5)(a)
the object and spirit of s. 111(5) is abused on an arm’s length acquisition of “actual” (albeit, not de jure) control of a Lossco

The non-capital losses of $90M, and other tax attributes of the taxpayer, were effectively sold to arm’s length investors pursuant to...

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Words and Phrases
group
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) avoidance of a de jure acquisition of a Lossco through acquiring “actual control” was abusive 591