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Army & Navy Department Stores Ltd. v. Minister of National Revenue, 53 DTC 1185, [1953] CTC 293, [1953] 2 S.C.R. 496-- summary under Subparagraph 251(2)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(2)- Paragraph 251(2)(c)- Subparagraph 251(2)(c)(i) shareholders do not indirectly own any of the corporation’s property One-half of the shares of the 5,000 shares of the “Western Company” were owned by the “Alberta company,” and the other half were owned by the “Saskatchewan company.” ...

The Humber College Institute of Technology & Advanced Learning v. ...

Addison & Leyen Ltd., 2007 DTC 5365, 2007 SCC 33, [2007] 2 S.C.R. 793-- summary under Subsection 160(1) Summary Under Tax Topics- Income Tax Act- Section 160- Subsection 160(1) delay in assessing under s. 160 not reviewable The taxation year of a corporation ("York") owned principally by one of the applicants ("Addison") ended on September 28, 1989 by virtue of a sale of York to a third party ("Senergy"). ...

R & C Commrs., [2012] EWCA Civ 927 (CA)-- summary under Tax Avoidance Summary Under Tax Topics- General Concepts- Tax Avoidance In order to shelter a capital gain which he had realized, the UK taxpayer purchased two options on the FTSE 100 index to be settled in cash: a put option (Option 1"); and a call option ("Option 2") with essentially the same strike price. ...

R & C Commrs v. Mertrux, [2012] UKUT 274 (Tax and Chancery Chamber)-- summary under Section 167.1 Summary Under Tax Topics- Excise Tax Act- Section 167.1 The taxpayer was a Mercedes dealer, licensed through Daimler-Chrysler UK ("DCUK"). ...

R & C Commrs v. Mertrux, [2012] UKUT 274 (Tax and Chancery Chamber)-- summary under Cumulative Eligible Capital Summary Under Tax Topics- Income Tax Act- Section 14- Subsection 14(5)- Cumulative Eligible Capital The taxpayer was a Mercedes dealer, licensed through Daimler-Chrysler UK ("DCUK"). ...

Collins & Aikman Products Co. v. The Queen, 2009 DTC 1179 [at at 958], 2009 TCC 299, aff'd 2010 DTC 5164 [at 7293], 2010 FCA 251-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) limited scope of PUC provisions reflected a policy choice The taxpayer ("Products"), which was a corporation resident in the U.S., transferred the shares of its subsidiary ("CAHL"), which was non-resident in Canada notwithstanding that it had been incorporated in Canada in 1929, to a newly incorporated Canadian-subsidiary of Products ("Holdings") in consideration for a common share of Holdings that had a paid-up capital equal to the fair market value of CAHL. ...

Lockyer & Anor (for Pawson Estate), [2013] UKUT 050 (Tax and Chancery Chamber)-- summary under Specified Investment Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Specified Investment Business actively-manged holiday property an investment The deceased taxpayer and her three children held equal interests in a bungalow ("Fairhaven"), which they rented out as a holiday property. ...

Lockyer & Anor (for Pawson Estate), [2013] UKUT 050 (Tax and Chancery Chamber)-- summary under Investment Business Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(1)- Investment Business actively-managed rental property an investment business The deceased taxpayer and her three children held equal interests in a bungalow ("Fairhaven"), which they rented out as a holiday property. ...

R & S Industries Inc. v. Canada (National Revenue), 2016 FC 275-- summary under Subsection 97(2) Summary Under Tax Topics- Income Tax Act- Section 97- Subsection 97(2) drop-down agreement interpreted as preventing a re-allocation of boot to avoid gain A transfer agreement for the drop-down under s. 97(2) of assets by the taxpayer (R&S) to a controlled LP specified that the elected amounts in a joint s. 97(2) election, and the respective portions of the Purchase Price allocated to the transferred assets, would be the minimum agreed amounts permitted under the Act, “provided …that in respect of the Goodwill, the elected amount shall, unless otherwise agreed be equal to $2,502,600.” ...