Lee v. Agence du revenu du Québec, 2020 QCCQ 780, aff'd sub nomine Seica v. Agence du revenu du Québec, 2021 QCCA 1401 -- summary under Tax Shelter

Summary Under
Tax Topics - Income Tax Act - Section 237.1 - Subsection 237.1(1) - Tax Shelter
tax shelter definition applied on a property-by-property basis, and cost excluded interest

A tax shelter, for the initial (2003/2004) years assessed by the ARQ, entailed the sale by a corporation (“Prospector”) to over 200 investors...

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Words and Phrases
cost
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(ii) interest on limited recourse notes that could be extinguished through the surrender of the limited recourse asset was deductible 226
Tax Topics - Income Tax Act - Section 143.2 - Subsection 143.2(6) limited recourse debt eliminated CCA claims 151