Toronto-Dominion Bank v. Canada, 2011 DTC 5125 [at at 6061], 2011 FCA 221, [2011] 6 CTC 19 -- summary under Subsection 248(10)
"series of transactions" must be pre-ordained absent s. 248(10)
A transitional provision in the Act provided that the old s. 55(1) would apply to a transaction if it were "part of a series of transactions,...
Words and Phrases
series of transactions or events| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Transitional Provisions and Policies | 163 | |
| Tax Topics - Income Tax Act - Section 112 - Subsection 112(3) | 174 | |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(9) | 117 | |
| Tax Topics - Statutory Interpretation - Ordinary Meaning | clear wording | 80 |