Fink v. Canada (Attorney General), 2018 FC 936, aff'd 2019 FCA 276 -- attach -- Shares
TSX-listed shares agreed to have discounted value to reflect blackout periods
Shares
10 June 2011 Roundtable, 2011-0404641C6 F - Shareholders Agreement and FMV -- attach -- Shares
examples of clauses reducing the FMV of freeze preferred shares
Louie v. The Queen, 2018 TCC 225, rev'd in part on "advantage" issue (for subsequent years) 2019 FCA 255 -- attach -- Shares
use of price range for share valuation was inappropriate where there was a second-by-second market
11 October 2013 APFF Roundtable, 2013-0495721C6 F - APFF 2013- Round table question 7 -- attach -- Shares
FMV is a question of fact within TCC's discretion
Mady v. The Queen, 2017 TCC 112 -- attach -- Shares
arm’s length sales price established FMV for closing-date internal transfer of same shares
ATR-17 9 February 1987 (Cancelled) -- attach -- Shares
public shares valued at 5-day average
Grimes v. The Queen, 2016 TCC 280 -- attach -- Shares
no discount for shareholder-level taxes, minority discount re NAL party’s voting control, marketability discount, advances valued at nil given practice of converting to bonuses
Montminy v. The Queen, 2016 TCC 110, rev'd 2017 FCA 156 -- attach -- Shares
capitalization of normalized cash flow accepted
UBS AG v Commissioners for HMRC; DB Group Services (UK) Ltd v. Commissioners for HMRC, [2016] UKSC 13 -- attach -- Shares
shares’ value reduced by contingent obligation to sell at discount to NAV
3 December 2015 External T.I. 2015-0593941E5 F - Allocation of the safe income on hand -- attach -- Shares
FMV of discretionary share increased at moment of dividend declaration to exclusion of other discretionary shares
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