Agence du revenu du Québec v. Samson, 2023 QCCA 332

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Summaries

Summary Under

date of Quebec agreement did not reflect the parties’ existing intention to realize a loss

The respondent (Samson) and a corporation (Bourgade) implemented a plan set out in a tax-planning memo of a tax advisor that contemplated that...

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Summary Under

no loss realized under s. 50(1)(b)(iii) unitl year end rectifed

An individual (Samson) and corporation (Bourgade) implemented a tax-planning memo that contemplated that they would transfer their shares of a...

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