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Cases

Fiducie famille Gauthier v. Canada, 2012 FCA 76, aff'g 2011 DTC 1343 [at 1917], 2011 TCC 318

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Tax Topics - Income Tax Act - Section 84.1 - Subsection 84.1(1) fees borne by transferee were "consideration" 318

Attridge v. The Queen, 91 DTC 5161 (FCTD)

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Winter v. The Queen, 89 DTC 5304 (FCTD)

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McPherson v. McPherson (1988), 48 DLR (4th) 577 (Ont CA)

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Brant Investments Ltd. v. Keeprite Inc. (1987), 37 BLR 65 (S.C.O.)

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Manning v. Harris Steel Group Inc., [1987] 1 WWR 86 (BCSC)

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Re Cyprus Anvil Mining Corp. (1986), 33 DLR (4th) 641 (BCCA)

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Buckingham v. Francis, [1986] 2 All E.R. 738 (Q.B.D.)

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Steen v. The Queen, 86 DTC 6498, [1986] 2 CTC 394 (FCTD), aff'd 88 DTC 6171, [1988] 1 CTC 256 (FCA)

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Terry v. The Queen, 85 DTC 5179, [1985] 1 CTC 135 (FCTD)

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Ronald Elwyn Lister Ltd. v. Dayton Tire Canada Ltd. (1985), 52 OR (2d) 88 (C.A.)

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Yager v. The Queen, 85 DTC 5494, [1985] 1 CTC 89 (FCTD)

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The Queen v. Landsman, 84 DTC 6278, [1984] CTC 274 (FCA)

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The Queen v. Hugh Waddell Ltd., 83 DTC 5309, [1983] CTC 270 (FCA)

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Stanton v. Drayton Commercial Investment Co. Ltd., [1982] BTC 269, [1982] 2 All E.R. 943 (HL)

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Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base 70

Carruthers v. The Queen, 82 DTC 6009, [1982] CTC 5 (FCTD)

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National System of Baking of Alberta Ltd. v. The Queen, 80 DTC 6178, [1980] CTC 237 (FCA)

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Connor v. The Queen, 78 DTC 6497, [1978] CTC 669, aff'd 79 DTC 5256, [1979] CTC 365 (FCA)

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Bendix Automotive of Canada Ltd. v. The Queen, 78 DTC 6137, [1978] CTC 194 (FCA)

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Corlite Petroleums Ltd. v. The Queen, 76 DTC 6450, [1976] CTC 766 (FCTD)

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West Estate v. Minister of Finance (B.C.), [1976] CTC 313 (BCSC)

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Rosenblat v. The Queen, 75 DTC 5274, [1975] CTC 472 (FCTD)

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Huron Steel Fabricators (London) Ltd. v. M.N.R., 75 DTC 5006, [1974] CTC 889 (FCTD)

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) 126

Smith Estate v. M.N.R., 74 DTC 6291, [1974] CTC 317 (FCTD)

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Henderson Estate v. M.N.R, 73 DTC 5471, [1973] CTC 636 (FCTD), aff'd 75 D.TC 5332, [1975] C.TC 485 (FCA)

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Winram v. MNR, 72 DTC 6187, [1972] CTC 193 (FCTD)

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Re Mann Estate, [1972] 5 WWR 23 (BCSC), aff'd [1973] CTC 561 (BCCA), aff'd [1974] CTC 222 (SCC)

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Beament et al. v. Minister of National Revenue, 70 DTC 6130, [1970] CTC 193, [1970] S.C.R. 680

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Lawson v. Minister of National Revenue, 69 DTC 5155, [1969] CTC 201, [1969] S.C.R. 587

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Attorney-General of Ceylon v. Mackie, [1952] 2 All E.R. 775 (PC)

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See Also

Mady v. The Queen, 2017 TCC 112

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 74.5 - Subsection 74.5(11) transfer from wife to higher-income husband was infused with his income-splitting purpose (as well as regulatory breach if she didn’t transfer) 355
Tax Topics - General Concepts - Ownership wife and children did not acquire beneficial interest in shares the taxpayer was to transfer to them, under tax plan, until the share transfer occurred 253
Tax Topics - Income Tax Act - Section 86 - Subsection 86(2) family members did not acquire beneficial interest in new shares until after completion of s. 86 reorg 285
Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b) - Subparagraph 69(1)(b)(i) contemporaneous arm’s length sale price established that shares previously transferred at undervalue 468
Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) was not responsible under s. 163(2) for the unbeknownst sharp practice of his tax advisor 658
Tax Topics - General Concepts - Price Adjustment Clause no jurisdiction to comment on application of price adjustment clause where the affected taxpayers are not appellants 223

Grimes v. The Queen, 2016 TCC 280

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Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(4) - Paragraph 104(4)(a) FMV determined with minority discount and without discount for shareholder taxes 186

Montminy v. The Queen, 2016 TCC 110

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Tax Topics - Income Tax Regulations - Regulation 6204 - Subsection 6204(1) - Paragraph 6204(1)(b) shares tainted by right to sell immediately after exercise to controlling shareholder 244

UBS AG v Commissioners for HMRC; DB Group Services (UK) Ltd v. Commissioners for HMRC, [2016] UKSC 13

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Tax Topics - General Concepts - Tax Avoidance unexpressed intention of Parliament to give relief for restrictive conditions attached to shares only where those conditions had a commercial purpose 531

Kruger Wayagamack Inc. v. The Queen, 2015 DTC 1112 [at 667], 2015 TCC 90, aff'd 2016 FCA 192

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Tax Topics - Income Tax Act - Section 251 - Subsection 251(2) - Paragraph 251(2)(b) - Subparagraph 251(2)(b)(i) de jure control requires strategic control, not merely operational control 83
Tax Topics - Income Tax Act - Section 256 - Subsection 256(1) - Paragraph 256(1)(a) de jure or de facto control requires strategic control, not merely operational control 314
Tax Topics - Income Tax Act - Section 256 - Subsection 256(1.2) - Paragraph 256(1.2)(c) effect of s. 256(1.2)(g) is as if company were run by 3rd party 236
Tax Topics - Income Tax Act - Section 256 - Subsection 256(5.1) de facto control requires strategic control, not merely operational control 200

Avrams v. The Queen, 2012 TCC 247

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Douglas Zeller and Leon Paroian Trustees of the Estate of Margorie Zeller v. The Queen, 2008 DTC 4441, 2008 TCC 426

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Lockhart v. The Queen, 2008 DTC 3044, 2008 TCC 156

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Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) 81

Laflamme v. The Queen, 2008 DTC 482, 2008 TCC 255

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Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) 196

McClintock v. The Queen, 2003 DTC 576, 2003 TCC 259

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Shepp v. The Queen, 99 DTC 510 (TCC)

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Dairy Queen Canada Inc. v. The Queen, 95 DTC 634 (TCC)

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Tax Topics - Income Tax Act - Section 212.1 - Subsection 212.1(1) 51

Husky Oil Ltd. v. The Queen, 95 DTC 316 (TCC), aff'd 95 DTC 5244 (FCA)

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Ritson Estate v. MNR, 93 DTC 1078 (TCC)

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Groupe d'Investissement Savoie, Lavoie Inc. v. M.N.R., 92 DTC 1531 (TCC)

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Tax Topics - Income Tax Act - Section 160 - Subsection 160(1) 120

Leung v. MNR, 92 DTC 1090 (TCC)

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Tax Topics - General Concepts - Effective Date 74

Holt v. Holt, [1990] 1 WLR 1250 (TCC)

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Taylor Estate v. MNR, 90 DTC 1777 (TCC)

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Mayson v. MNR, 85 DTC 341, [1985] 1 CTC 2395 (TCC)

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Curry Estate v. U.S., 83-1 U.S.TC ¶13:518 (5th. C.A. 1983)

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Ahmanson Foundation v. U.S., 81-2 U.S.TC ¶13:438, 674 F. 2d 761 (9th C.A. 1981)

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Fiddes Estate v. MNR, 70 DTC 1117, [1970] Tax A.B.C. 156

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Barber Estate v. MNR, 66 DTC 315, 41 Tax A.B.C. 27

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Administrative Policy

3 December 2015 External T.I. 2015-0593941E5 F - Allocation of the safe income on hand

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Tax Topics - Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) flexible allocation of SIOH where discretionary common shares 1215
Tax Topics - Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(b) quaere whether 8% reduction is significant 19

4 May 2015 External T.I. 2013-0502761E5 F - Stock Options and Earnout

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Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(a) FMV of shares at time of stock option exercise determined by valuing earn-out clause in subsequent sales agreement 201

10 October 2014 APFF Roundtable, 2014-0538121C6 F - Détermination de la JVM des actions

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10 October 2014 APFF Roundtable Q. 26, 2014-0538201C6 F - 2014 APFF Roundtable, Q. 26 - Cost of property

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Words and Phrases
fair market value
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Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) arm's length transfer price prevails over FMV 176
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(3) - Subparagraph 247(3)(a) - Subparagraph 247(3)(a)(iii) general requirement for penalty elimination re transfer pricing capital setoff adjustment 140

28 November 2010 CTF Roundtable, 2013-0487431C6 - Value of Vote-Only Shares – 2010 CTF Conference

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5 October 2012 APFF Roundtable, 2012-0454061C6 F - Transfer of a Lossco to a related corporation

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16 December 2003 Internal T.I. 2003-04616 -

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Tax Topics - Income Tax Act - Section 50 - Subsection 50(1) 104

28 June 2001 External T.I. 2001-007320 -

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IT-113R4 "Benefits to Employees-Stock Options"

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24 November 1997 T.I. 972284

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14 October 1997 T.I. 970653

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Tax Topics - Income Tax Act - Section 146 - Subsection 146(8.8) 64

24 July 1997 T.I. 971601

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1 May 1997 T.I. 963998

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3 December 1993 T.I. 920099 [no discount for future taxes]

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93 C.R. - Q. 47

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13 January 1993 T.I. (Tax Window

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Tax Professionals Mini Round Table - Vancouver - Q. 4 (March 1993 Access Letter, p. 102)

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1993 Conference for Advance Life Underwriting, Q. 13 (931011) (C.T.O. "CALU Ques. 13-Buy-Sell Agreement & Valuation of Shares")

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1992 A.P.F.F. Annual Conference, Q. 11 (January - February 1993 Access Letter, p. 54)

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10 February 1992 T.I. (Tax Window, No. 16, p. 12, ¶1742)

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(15) 100

20 November 1991 T.I. (Tax Window, No. 13, p. 19, ¶1603)

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4 October 1991 T.I. (Tax Window, No. 10, p. 16, ¶1498)

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Tax Topics - Income Tax Act - Section 212 - Subsection 212(2) 57

23 and 29 August 1991 T.I. (Tax Window, No. 8, p. 20, ¶1411)

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24 July 1991 T.I. (Tax Window, No. 7, p. 11, ¶1369)

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14 June 1991 T.I. (Tax Window, No. 4, p. 11, ¶1309) [maintaing value of preferred sahres]

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Harris, "An Update of Revenue Canada's Approach to the Butterfly Reorganization", 1991 Conference Report

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15 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 14, ¶1078)

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30 April 1990 T.I. (September 1990 Access Letter, ¶1419)

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19 April 1990 T.I. (September 1990 Access Letter, ¶1433)

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18 April 1990 T.I. (September 1990 Access Letter, ¶1430)

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1 March 1990 T.I. (August 1990 Access Letter, ¶1384)

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October 1989 A.P.F.F. Round Table - Q.9 (Jan. 90 Access Letter, ¶1075)

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October 1989 Revenue Canada Round Table - Q.18 (Jan. 90 Access Letter, ¶1075)

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ATR-22R (14 April 89)

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ATR-36 (4 Nov. 88)

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87 C.R. - Q.37

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87 C.R. - Q.38

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ATR-17 9 February 1987 (Cancelled)

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Tax Topics - Income Tax Act - Section 32.1 - Subsection 32.1(1) deduction for employer portion of previous contributions to employee stock purchase plan 422

81 C.R. - Q.35

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81 C.R. - Q.45

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81 C.R. - Q.53

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80 C.R. - Q.13

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80 C.R. - Q.15

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80 C.R. - Q. 52

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IC 89-3 "Policy Statement on Business Equity Valuations"

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Tax Topics - Income Tax Act - Section 70 - Subsection 70(5) 19

IT-269R3 "Part IV Tax on Taxable Dividends Received by a Private Corporation or a Subject Corporation"

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Tax Topics - Income Tax Act - Section 186 - Subsection 186(4) 0

IT-140R3 "Buy-Sell Agreements"

IT-96R5 "Options Granted by Corporations to Acquire Shares, Bonds or Debentures" under "Shareholder Benefit"

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) 0

Articles

Shaun Doody, "The Effect of Embedded Capital Gains on Fair Market Value", Tax Litigation, 2011, p. 1094

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Alan MacNaughton, Amin Mawani, "CRA: Employee Stock Options TFSAs", Canadian Tax Highlights, Vol. 17, No. 5, May 2009

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David Lewy, "Valuation and Family-Business Share Structures - Some Musings", CCH Tax Topics, No. 1920, 16 October 2008, p. 1

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Donald N. Cherniawsky, "Further Comments on Revenue Canada's Approach to Exclusionary Dividend Shares: The Shepp case", Business Vehicles, Vol. V, No. 2, 1999, p. 238.

D.M. Chernawsky, "Revenue Canada Issues Valuation, on Exclusionary Dividend Shares", Business Vehicles, Vol. IV, No. 4, 1998, p. 210.

Wolfe D. Goodman, "American Family Limited Partnerships as an Estate Planning Tool?", Goodman on Estate Planning, Vol. VI, No. 3, 1997, p. 454

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Sutherland, "The Valuation for Tax Purposes of Controlling Holdings of Unquoted Shares", British Tax Review, 1996, No. 4, p. 397.

Dorner, "Reality Check", CA Magazine, August 1995, p. 54

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Bradley, "Forward Participation Shares - Emerging Income Tax Issues", 1991 Conference Report, p. 8:2.

Wise, "The Valuation of Preferred Shares Issued on a Section 85 Rollover", 1984 Canadian Tax Journal, March-April, p. 239.

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Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) 0

Wise, "Valuation Aspects of Shareholders' Buy-Sell Agreements", 1984 Conference Report, p. 1013.

Wise, "Fair Market Value Determinations - A Few More Requirements", 1983 Canadian Tax Journal, May-June, p. 337.

Wise, "Valuation and the Income Tax Act", 1981 Canadian Tax Journal, September-October, p. 626.

Wise, "The V-Day Value of Publicly Traded Shares", 1980 Canadian Tax Journal, May-June, p. 253.