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. … Where a trust transfers property, it is a disposition. This is true even if the transfer is to a beneficiary or another trust with identical beneficiaries: subparagraphs (e)(i) to (iii) of the definition of disposition in s. 248(1). ...

Furthermore, since in light of s. 251(6)(b) “a marriage ends on the death of one of the individuals … [t]o have the same rules apply to individuals in a common-law partnership, that relationship would also have to cease upon the death of one of the partners” (para. 44). ...

. … She further found that the phrase "a right of any kind whatever" did not expand the ordinary meaning of "property" to include a non-exclusive, commonly held right to carry on a business, such as that held by the taxpayer. ...

Canada, 2018 FCA 121-- summary under Subsection 248(28) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(28) potential for double taxation under the ITA of NAL transactions The taxpayer, a Canadian exploration company, unsuccessfully argued that it was not subject to Part XII.6 tax on Canadian exploration expenses (“CEE”) that it had purported to renounce under the look-back rule- but which were now admittedly not eligible for look back because the flow-through share investors were non-arm’s length – because the reference in Part XII.6 to CEE that it “purported” to renounce under the rule referred only to expenses which had been validly rather than invalidly renounced under the look-back rule. ...

Regarding the Minister's argument that Article 13 was only included "for greater certainty," Sharlow J.A. stated: The OECD model conventions, including the Canada-Austria Income Tax Convention, generally have two purposes – the avoidance of double taxation and the prevention of fiscal evasion. ...

. … Grenon RRSP was obligated to file a return under Part I reporting taxable income. ...

In my view, the issue is not new …. However, even if it were a new issue, I am satisfied there is a sufficient basis in the record to resolve the issue and we have a duty to do so to ensure justice is done. ...

The Tax Court’s finding was consistent with the 2003 OECD Commentaries, which indicated that a company is not normally the beneficial owner of dividends if, though the formal owner, it only has “very narrow powers … in relation to the income concerned” (quoted at para. 94). ...

(Noël, J.A. also noted (at para. 69) that the " the same terminal loss would have been realized if the limited partners, rather than proceeding with the transactions in issue, had simply dissolved the partnership and distributed the partnership assets to the partners. ...

. … Because each taxpayer is assessed (or reassessed) separately, this can result in inconsistent assessments (Peterson v. ...