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Canada, 2023 SCC 16-- summary under Subsection 248(10) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(10) series includes transactions undertaken before or after the series in relation to the series In the course of a general discussion, Rowe J stated (at para. 55): A series of transactions also includes “related transactions or events... in contemplation of the series” (s. 248(10)), which refers to transactions or events before or after the series which were undertaken “‘in relation to’ or ‘because of’ the series” (Copthorne, at para. 46, citing Trustco, at para. 26). ...

Canada, 2023 SCC 16-- summary under Subsection 256(5.1) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(5.1) lender to distressed corporation may have de facto control In discussing the broader scope of the concept of de facto control under s. 256(5.1) as contrasted to that of de jure control under s. 111(5), Rowe J stated (at para. 93): Such a test would have captured a variety of situations far beyond Parliament’s concern for ensuring that one taxpayer would not benefit from another’s losses. ...

Canada, 2023 SCC 16-- summary under Subsection 111(5) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(5) rationale of s. 111(5) addresses where there is a change in the identity of those behind a corporation The non-capital losses of $90M, and other tax attributes (the “Tax Attributes”) of the taxpayer, were effectively sold to arm’s length investors pursuant to transactions under which: The existing shareholders of the taxpayer exchanged their shares for shares of a “Newco” under a Plan of Arrangement A venture capital company facilitator (Matco) entered into an “Investment Agreement” with the taxpayer and Newco pursuant to which Matco (principally in consideration for $3M in cash) acquired a debenture of the taxpayer that was convertible into shares representing 79% of its equity shares but only 35% of its voting shares. ...

Canada, 2023 SCC 16-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) a transaction where a Lossco became subject to control rights similar to de jure control abused the rationale of s. 111(5) The non-capital losses of $90M, and other tax attributes (the “Tax Attributes”) of the taxpayer, were effectively sold to arm’s length investors pursuant to transactions under which: The existing shareholders of the taxpayer exchanged their shares for shares of a “Newco” under a Plan of Arrangement A venture capital company facilitator (Matco) entered into an “Investment Agreement” with the taxpayer and Newco pursuant to which Matco (principally in consideration for $3M in cash) acquired a debenture of the taxpayer that was convertible into shares representing 79% of its equity shares but only 35% of its voting shares. ...