Separate Existence

Cases

Loblaw Financial Holdings Inc. v. Canada, 2020 FCA 79

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Investment Business - Paragraph (a) a Barbados bank sub conducted its business of investing in short-term debt principally with arm’s length persons 580
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business receipt of equity funds from parent was not part of Barbados bank’s business 178
Tax Topics - Statutory Interpretation - Redundancy/reading in words error to apply an unexpressed intention 160
Tax Topics - Statutory Interpretation - Drafting Style no additional requirements should be inferred in legislation drafted with “mind-numbing detail” 160
Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Foreign Accrual Property Income fundamental purpose of FAPI is to capture passive income 158

Brunette v. Legault Joly Thiffault, s.e.n.c.r.l., 2018 SCC 55

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - General Concepts - Negligence, Fiduciary Duty and Fault a shareholder generally cannot sue for bad tax advice provided to the corporation 360

Anthony v. Canada (National Revenue), 2016 FC 955

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Computation of Profit matching principle not a rule of law 226
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.2) s. 152(4.2) denials are subject to judicial review 123

Envision Credit Union v. Canada, 2013 DTC 5144 [at 6275], 2013 SCC 48, [2013] 3 S.C.R. 191

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - General Concepts - Illegality lawful interpretation preferred 260
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1) all predecessors' property became Amalco property, and purported conveyance of only some of their property to Amalco was legally impossible 393

Desnomie v. Canada, 2000 DTC 6250 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Colbert v. The Queen, 94 DTC 6620 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - General Concepts - Agency shareholder generally does not carry on business of corporation 132
Tax Topics - General Concepts - Personality 132
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Former Business Property 58

The Queen v. Jennings, 94 DTC 6507 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - General Concepts - Personality 80

The Queen v. MerBan Capital Corp. Ltd., 89 DTC 5404 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

14 February 2014 External T.I. 2013-0504601E5 F - Bénéfices de fabrication et de transformation

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 125.1 - Subsection 125.1(3) - Manufacturing or Processing - Paragraph (c) construction exclusion avoided if road asphalt is produced by related corp 150