Words and Phrases - "hold"
Thye RRSP of James T. Grenon (552-53721) by its Trustee CIBC Trust Corporation v. Canada, 2025 FCA 129
distribution of units to minors so as to fail to achieve the targeted minimum of qualified investors purchasing under an offering memorandum was not a lawful distribution
The appellant subscribed $310 million for units of various income funds, which were intended to qualify as mutual fund trusts on the basis that...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 207.1 - Subsection 207.1(1) | since FMV of non-qualified investments was required to be included in the annuitant’s income (even though such inclusion was not reported or assessed) it was excluded from Pt. XI.1 tax | 360 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(3.1) | assessment of group RRSP return focused on Pt. XI.1 tax reporting did not start the Pt. I normal reassessment period running | 279 |
| Tax Topics - Other Legislation/Constitution - Federal - Federal Courts Act - Section 27 - Subsection 27(1.3) | FCA raised the correctness of (and reversed) a TCC finding that was not challenged by the parties | 420 |
| Tax Topics - Income Tax Act - Section 146 - Subsection 146(10.1) | RRSP must recognize losses on non-qualified investments but such losses, if capital losses, cannot be deducted from property income from such investments | 153 |
| Tax Topics - Statutory Interpretation - Consistency | presumption that same word has same meaning, and different words have different meanings throughout the ITA | 233 |
| Tax Topics - Statutory Interpretation - Ordinary Meaning | meaning of “distribution” informed by provincial securities law | 161 |
| Tax Topics - Statutory Interpretation - French and English Version | 2-step approach to reconciling 2 versions | 298 |
25 September 2014 External T.I. 2012-0451411E5 F - Mutual Holding Corporation
Summary Under
Tax Topics - Income Tax Act - Section 139.1 - Subsection 139.1(1) - Mutual Holding Corporation"holding" must be direct holding
Does a mutual corporation qualify as a mutual holding corporation if it holds shares of the insurance corporation indirectly? After quoting from...
Words and Phrases
hold| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 139.1 - Subsection 139.1(1) - Mutual Holding Corporation | “holding” refers to direct holding/this purpose is a question of fact | 137 |