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immediately after

Summary Under

"immediately after disposition" does not refer to at the end of the series, where various intervening transactions constituting a series

It was submitted that where a taxpayer transfers property to a corporation that is controlled by the taxpayer and shortly thereafter the taxpayer...

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Words and Phrases

Full Title

Terminal Norco Inc. v. The Queen, 2006 DTC 2897, 2006 TCC 139

Summary Under

taxpayer controlled subsidiary immediately after drop-down transaction notwithstanding pre-ordinated sale of the subsidiary's shares

In order to avoid Quebec mutation tax, the taxpayer transferred the assets of a business division to a newly-incorporated wholly owned subsidiary...

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Words and Phrases