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Merritt v. MNR (1941), 2 DTC 513 (Ex Ct), rev'd [1942] SCR 269, 2 DTC 561 -- summary under Subsection 84(2)

MNR (1941), 2 DTC 513 (Ex Ct), rev'd [1942] S.C.R. 269, 2 DTC 561-- summary under Subsection 84(2) Summary Under Tax Topics- Income Tax Act- Section 84- Subsection 84(2) The Premier Trust Company ("Premier") acquired all the shares of the taxpayer and other shareholders of the Security Loan and Savings Company ("Security") in consideration for (at the option of the shareholder) 1.5 shares of Premier for each Security share, or a combination of cash of $102 and 0.5 shares of Premier for each Security share. ...

Crown Forest Industries Ltd. v. Canada, 95 DTC 5389, [1995] 2 SCR 802, [1995] 2 CTC 64 -- summary under Article 4

Canada, 95 DTC 5389, [1995] 2 SCR 802, [1995] 2 CTC 64-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Some of the income derived from a corporation incorporated in the Bahamas was effectively connected with the conduct by it of a business in the United States. ...

McNeill v. The Queen, 86 DTC 6477, [1986] 2 CTC 352, [1986] 2 CTC 364, [1986] DTC 6486 (FCTD) -- summary under Paragraph 6(1)(a)

The Queen, 86 DTC 6477, [1986] 2 CTC 352, [1986] 2 CTC 364, [1986] DTC 6486 (FCTD)-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) A Quebec air traffic controller received from his employer, the federal government, the sum of $15,571 to compensate for house mortgage expenses that he might incur outside Quebec, and the sum of $2,155 which was computed as a percentage of his income, as part of a Department of Transport policy to seek to relocate controllers with anglophone ancestry to outside Quebec so as to avoid labour relations problems. ...

Reference re Goods and Services Tax, [1992] 2 SCR 445, [1992] GSTC 2 -- summary under Section 125

Reference re Goods and Services Tax, [1992] 2 SCR 445, [1992] GSTC 2-- summary under Section 125 Summary Under Tax Topics- Other Legislation/Constitution- Constitution Act, 1867- Section 125 imposing a GST collection obligation on the Province on supplies made by it did not violate s. 125 In finding that the ETA, Pt. ...

Canada v. Antosko, 94 DTC 6314, [1994] 2 S.C.R. 312, [1994] 2 CTC 25 -- summary under Subsection 20(14)

Antosko, 94 DTC 6314, [1994] 2 S.C.R. 312, [1994] 2 CTC 25-- summary under Subsection 20(14) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(14) On March 1, 1975 the taxpayers acquired all of the common shares of the New Brunswick Industrial Finance Board in a company that manufactured charcoal briquettes for $1 and agreed to operate the company for the following two years in consideration for the agreement of the Board to postpone the obligation to pay principal and interest in excess of $5 million of indebtedness owing by the Company to the Board, and the Board's agreement that upon expiration of the two-year period it would sell such indebtedness and accrued interest to the taxpayers for $10. ...

2 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 20, ¶1071) -- summary under Subsection 48(3)

2 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 20, ¶1071)-- summary under Subsection 48(3) Summary Under Tax Topics- Income Tax Act- Section 48- Subsection 48(3) Where a person holds a capital interest in a trust at the time of becoming a resident of Canada, the ACB of that interest is its fair market value at the time he became a resident. ...

2 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 11, ¶1049) -- summary under Paragraph 113(1)(a)

2 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 11, ¶1049)-- summary under Paragraph 113(1)(a) Summary Under Tax Topics- Income Tax Act- Section 113- Subsection 113(1)- Paragraph 113(1)(a) Interest paid by U.S. subsidiary which is recharacterized as a dividend for U.S. purposes will be taxed as interest income in the hands of the Canadian parent. ...

2 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 14, ¶1080) -- summary under Subsection 74.4(2)

2 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 14, ¶1080)-- summary under Subsection 74.4(2) Summary Under Tax Topics- Income Tax Act- Section 74.4- Subsection 74.4(2) The purpose test in s. 74.4(2) must be applied separately to each transfer of property, with the result that imputed income on a transfer which does not meet the purpose test effectively cannot be off-set by excess income received as the result of a transfer of property that does not violate the purpose test. ...

2 November 2023 APFF Roundtable Q. 2, 2023-0982751C6 - Meaning of purpose tests in paragraph 55(2.1) -- summary under Paragraph 55(2.1)(b)

2 November 2023 APFF Roundtable Q. 2, 2023-0982751C6- Meaning of purpose tests in paragraph 55(2.1)-- summary under Paragraph 55(2.1)(b) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(b) the payment of a pre-closing dividend of significant excluded assets by the target to its parent likely would engage s. 55(2) where no safe income A corporation resident in Canada ("Parent") owning 100% of "Target" accepts an offer from an unrelated third party ("Purchaser") to purchase all of the Target shares for $3 million, with the sale agreement specifying that assets which Purchaser does not wish to acquire ("Excluded Assets") are assigned a value of zero. ...

Slate Retail/ SUSO 2/GAR -- summary under REIT Mergers

The SUSO 2 declaration of trust will be amended to add a right of SUSO 2 to redeem SUSO 2 Units by delivering SUSO 1 class U units. SUSO 1 will acquire all of the assets of SUSO 2 in consideration for SUSO 1 class U units. SUSO 2 will redeem all SUSO 2 Units (except for any SUSO 2 Units acquired by SUSO 1) by delivering SUSO 1 class U units to SUSO 2 Unitholders. ...

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