Subsection 194(4) - Corporation may designate amount
Cases
Groupmark Canada Ltd. v. The Queen, 93 DTC 5179, [1993] 1 CTC 234 (FCTD)
A related corporation issued a non-interest bearing promissory note for $120,000 to the taxpayer on May 18, 1984. Given that advances in excess of...
Words and Phrases
considerationSubsection 194(4.2) - Where amount may not be designated
Cases
Mort v. The Queen, 93 DTC 5058, [1993] 1 CTC 99 (FCTD)
The requirements of s. 194(4.2)(b) were met given that the steps that had been taken by April 10, 1984 "were meaningful, significant and...
First Fund Genesis Corp. v. The Queen, 91 DTC 5361, [1991] 2 CTC 14 (FCTD)
After finding that s. 194(4.2) had retroactive effect to the date that the restriction was first announced on October 10, 1984 by the Minister of...
Words and Phrases
substantially advanced| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc. | 61 | |
| Tax Topics - Statutory Interpretation - Retroactivity/Retrospectivity | 67 |
See Also
Gupta v. MNR, 92 DTC 1542 (TCC)
A document filed by the taxpayer with a Quebec securities commission which did not qualify as a prospectus for purposes of the Quebec Securities...
Subsection 194(7) - Late designation
Cases
The Queen v. United Equities Ltd., 95 DTC 5042, [1995] 1 CTC 164 (FCA)
The taxpayer successfully argued that timely filing of information returns is not a condition precedent to late the filing of a designation under...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Resolving Ambiguity | 53 |