Silicon Graphics Ltd. v. Canada, 2002 DTC 7113, 2002 FCA 260 -- summary under Canadian-Controlled Private Corporation
Summary Under
Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Canadian-Controlled Private CorporationU.S. public shareholders not a group; no de facto control by lender/licensor
The taxpayer, which was a Canadian corporation with Canadian management, had effected a public offering of its common shares in the U.S. as a...
Words and Phrases
group| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 256 - Subsection 256(5.1) | must be right to affect board or directly influence shareholders | 187 |
| Tax Topics - Income Tax Act - Section 256 - Subsection 256(6) | 65 | |
| Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. | 23 | |
| Tax Topics - Statutory Interpretation - Interpretation Act - Subsection 45(2) | 56 | |
| Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc. | 64 |