Related Companies

Cases

The Queen v. Parsons, 84 DTC 6447, [1984] C.T.C 354, 84 DTC 6452 (FCA)

It was found by the trial judge that management companies, which two professional engineers ("Parsons" and "Vivian") had incorporated and...

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Sham no sham as purported legal rights were created 117
Tax Topics - General Concepts - Tax Avoidance no sham as purported legal rights were created 117
Tax Topics - Income Tax Act - Section 9 - Related Companies 117

The Queen v. Daly, 81 DTC 5197, [1981] CTC 270 (FCA)

The purported interposition between the taxpayer and his employer of a management corporation was legally ineffective, and thus, also ineffective...

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Mendels v. The Queen, 78 DTC 6267, [1978] CTC 404 (FCTD)

A partnership of two dentists determined that the value of administrative services performed by them was $20,000, and 'by means of' appropriate...

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Dominion Bridge Co. Ltd. v. The Queen, 75 DTC 5150, [1975] CTC 263, aff'd 77 DTC 5367, [1977] CTC 554 (FCA)

The amounts paid by a wholly-owned Bermudan subsidiary ("Span") for purchases of steel were found to constitute the taxpayer's cost of that steel,...

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Holmes v. The Queen, 74 DTC 6143, [1974] CTC 156 (FCTD)

The wives of the partners of a law firm incorporated a company ("Irish") which acquired all the equipment and furniture of the partnership,...

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See Also

Harvey v. The Queen, 98 DTC 1089 (TCC)

The taxpayer was allowed to deduct fees charged to his dental practice equal to 115% of the eligible costs specified in a May 1985 letter of the...

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Administrative Policy

2015 Ruling 2013-0513411R3 F - Société de professionnels

An individual carrying on a professional practice will transfer various employees to a family corporation, with the corporation then charging him...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose fees paid by professional practice to family management company 420

25 March 1996 External T.I. 9608245 - MANAGEMENT COMPANY FEES

In response to an inquiry as to what percentage of mark-up on cost Revenue Canada would accept as a reasonable management fee corporate expense...

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21 October 1991 TI 912692 (Tax Window, No. 12, p. 22, 1545)

Management fees paid by a professional practitioner to a related corporation generally will be considered deductible if they do not exceed 115% of...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Related Companies 49

19 September 1990 TI 902240

Where, in order to avoid GST on services provided by a management services corporation for a professional practice, the employees work directly...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Related Companies 74

85 CR - Q.18

RC will regard fees charged by a management services corporation as reasonable if they do not exceed 115% of the cost of providing the management...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Related Companies 38

84 CR - Q.76

The reasonableness of service fees charged by management companies is determined by RC in light of all the facts and circumstances, and no...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Related Companies 27

IT-189R2 "Corporations Used by Practising Members of Professions"

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Related Companies 0