Words and Phrases - "distribution"
10 October 2003 Roundtable, 2003-0035665 F - TRANSFER D'UNE POLICE D'ASSURANCE-VIE
A corporation transfers a policy on the life of an arm’s length shareholder for consideration equal to the policy’s fair market value, which...
Grenon v. The Queen, 2021 TCC 30
In order that the taxpayer’s RRSP could indirectly invest in operating businesses in which he and/or two business colleagues had a management...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | purported establishment of “alter ego” MFTs through which an RRSP could invest in operating businesses was an abuse engaging GAAR | 605 |
| Tax Topics - Income Tax Act - Section 204.2 - Subsection 204.2(1.1) | alleged distribution from non-qualified investment was not an over-contribution | 277 |
| Tax Topics - General Concepts - Window Dressing | window-dressing is a deception about intention | 312 |
| Tax Topics - Income Tax Act - Section 207.1 - Subsection 207.1(1) | non-qualified investments not “included” in annuitant’s income because it was never assessed | 346 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) | CRA’s assessing listed taxable RRSPs in a T3GR global return was not of the taxpayer’s (also listed) RRSP /inappropriate reliance in legal opinion on certificate of fact was carelessness | 441 |
| Tax Topics - Income Tax Act - Section 207.2 - Subsection 207.2(3) | CRA’s assessment of Pt. XI.1 shown on the T3GR for all RRSPs of one type did not start the normal reassessment period for the taxpayer’s RRSP since no tax shown for it | 370 |
| Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(d.2) | distribution was not lawful because the issuer had not complied with the OM exemption, which was the exemption that it had chosen to rely on | 290 |
Canada v. Repsol Energy Canada Ltd., 2017 FCA 193
The taxpayers were the partners of a limited partnership which constructed a terminal and jetty in St. John to which liquid natural gas would be...
19 December 2013 External T.I. 2013-0503481E5 - Distribution of property by a trust
After referring to 2013-0488061E5 (below) and 2013-0488381E5, CRA stated:
[A] transfer of property by a trustee in settlement of a debt cannot...
Repsol Canada Ltd. v. The Queen, 2015 TCC 21, aff'd 2017 FCA 193
The taxpayers were related companies, and the general partner and a 75% limited partner of a partnership which constructed a terminal and jetty in...
Stursberg v. The Queen, 93 DTC 5271, [1993] 2 CTC 76 (FCA)
The other partners of the partnership consented to a reduction in the taxpayer's partnership interest from 40% to 15%, and to an increase in the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | partial disposition of partnership interest to a related corporation, even though proceeds run through the partnership | 114 |