ARQ v. Kone Inc., 2024 QCCA 678

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Summaries

Summary Under

repo produced results consistent with it not being a loan form of financing and with the policy behind exempt surplus dividends

The taxpayer (“KQI”), a Canadian operating subsidiary in the Kone multinational group, used group funds advanced to it by a group company...

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Summary Under

agreement to treat a repo as a loan for US tax purposes did not support “sham”

The taxpayer (“KQI”), which was a Canadian operating subsidiary in a group ultimately controlled by a Finnish parent, used funds that had been...

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