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S. 56(2) did not apply to redistribute $8,000 (= $10,000 x 400/500) of the $10,000 dividend received by Mrs. ...

It was also irrelevant that the taxpayer did not object to the 2009 reassessment, because " Canadian Marconi is strong authority that an out-of-time reassessment is void absent an allegation of fraud or misrepresentation" (para. 62). ...

Lehigh Cement Limited, 2014 DTC 5058 [at at 6849], 2014 FCA 103, aff'g 2013 DTC 1139 [at 740], 2013 TCC 176-- summary under Paragraph 95(6)(b) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(6)- Paragraph 95(6)(b) restricted to status-manipulating acquisitions or dispositions The taxpayer ("CBR Canada") directly (as to 99%) and indirectly (through a wholly-owned Alberta subsidiary as to 1%) used $US 100 million borrowed from two arm's length non-resident banks (with the principal but not the interest obligation under the first loan then being assigned by the first bank to a Belgian subsidiary of the taxpayer's ultimate Belgian parent – "CBR SA") by making capital contributions to a US LLC, which used those funds to make interest-bearing loans to a U.S. sister corporation ("CBR US") of CBR Canada. ...

. … …[T]he letter…was an amendment to the estate's tax return and its effect was to amend the initial return. ...

. … Once the general operation of the GST Act is understood in that way, it is apparent that there is no warrant in the text or policy of the GST Act for reading the reference in the special rule in s 40-35 to a supply of "residential premises" that is a supply "by way of lease" as referring to the supply which occurs at the time of entering into the lease but not as referring to the further supply which occurs by means of the lessor observing and continuing to observe the express or implied covenant of quiet enjoyment under the lease. ...

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. ...

Although Mehjoo was resident in the UK, he might have been able to utilize a bearer warrant scheme ("BWS ") to avoid capital gains tax on his sale of shares of a UK private company on the basis that he was domiciled outside the UK. ...

The articles of Melru left the amount of dividends to be declared on the Class F and G shares largely in the discretion of the director, except that: dividends on the Class G shares could not exceed a return of prime + 1% on their redemption price; and after dividends of $0.01 per share were paid on the Class F share, dividends of $0.01 per share were required to be declared on the common shares before further dividends on the Class F shares could be declared. ...

On appeal to the Court of Appeal, the Minister raised several new arguments, including that: the transactions were abusive of ss. 3, 4, 9 and 111, an underlying policy of which is that business loss claims should reflect actual losses; the taxpayer's purported losses were not business losses, given that the shares were not acquired as inventory or as part of and adventure or concern in the nature of trade (see "Rollover and other non-trading transactions "); and to the extent that the taxpayer had any losses, they were capital in nature. ...

EBI exercised the same daily control of the individuals' activities after the change as before (and subsequently, after the new arrangements were terminated) through detailed daily reporting, detailed monitoring by its foremen and strict controls on how its trucks (which were owned by EBI) were utilized and parked – as well as the individual corporations themselves being administered by EBI's accountants for a fixed fee and having the same address as EBI. ...