Gerbro Holdings Company v. Canada, 2016 TCC 173, briefly aff'd 2018 FCA 197 -- summary under Subsection 94.1(1)
offshore hedge fund investments were chosen in the main for commercial reasons (e.g., manager reputation), so that s. 94.1 did not apply
The taxpayer (“Gerbro”) was a Canadian investment corporation (owned by a family trust but with an elderly income beneficiary, so that Gerbro...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Onus | no taxpayer burden to displace assumptions of mixed fact and law | 71 |
| Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. | Minister's statement was false | 130 |
| Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Rules (General Procedure) - Section 145 - Subsection 145(3) | expert's report did not include all the underlying data | 115 |