Gillen v. The Queen, 2017 TCC 163, aff'd 2019 FCA 62 -- summary under Ownership
Summary Under
Tax Topics - General Concepts - Ownershiptest of beneficial ownership
A limited partnership was found to have immediately transferred the beneficial ownership of applications to the Saskatchewan government for potash...
Words and Phrases
beneficial ownership| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 110.6 - Subsection 110.6(14) - Paragraph 110.6(14)(f) - 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 | 364 |
| Tax Topics - General Concepts - Effective Date | relation-back theory applied: closing retroactively confirmed previous beneficial ownership transfer | 255 |