Gillen v. The Queen, 2017 TCC 163, aff'd 2019 FCA 62 -- summary under Subparagraph 110.6(14)(f)(ii)

property was not used in a business for s. 110.6(14)(f)(ii) purposes when it was beneficially acquired and dropped-down on the same day

A corporation (“Kinderock”) owned by the taxpayer and his wife applied, commencing on October 4, 2007, to the Saskatchewan government for...

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Ownership test of beneficial ownership 112
Tax Topics - General Concepts - Effective Date relation-back theory applied: closing retroactively confirmed previous beneficial ownership transfer 255