RC cautioned that in Dorcas v. MNR, 91 DTC 350 the Tax Court indicated that past events cannot be altered ab initio by steps taken ex post facto.
The extended meaning of "control" in s. 186(2) may also apply in determining whether corporations are connected for purposes of the definition of qualified small business corporation share.
An unsecured non-interest bearing loan with no specific terms of repayment would qualify under the concept of "indebtedness" introduced by S.C. 1991, c. 49.
Email this Content