Words and Phrases - "arrangement"

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29 May 2008 External T.I. 2007-0262591E5 F - Remboursement de sommes versées par erreur

s. 8(1)(n) could extend to reimbursements of disability benefits to an employer-arranged insurer

After disability payments to the taxpayer, under the policy taken out by the employer with an insurer, were suspended, then retroactively...

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Words and Phrases
arrangement

Canada v. Canadian Pacific Ltd., 2002 DTC 6742, [2002] 3 F.C. 170, 2002 FCA 98

an aspect of a transaction is not a transaction

The Crown argued that CP's act of denominating the debentures in Australian dollars was in and of itself a transaction and that it amounted to an...

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Words and Phrases
transaction arrangement
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) primary purpose of a borrowing in a tax-advantageous currency was to raise money 290
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) transaction not to be recharacterized until after a determination of abuse 283

5 October 2012 Roundtable, 2012-0454021C6 F - Expiration d'un arrangement

purpose of Reg. 6205(2) re estate freezes and employees

An employee who subscribed directly for treasury shares, and subsequently transferred them to a new corporation could benefit from the Reg 6205(2)...

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Words and Phrases
arrangement

Cameco Corporation v. The Queen, 2018 TCC 195, aff'd 2020 FCA 112

As part of a preliminary discussion of s. 247(2), Owen J stated (at para. 677):

An “arrangement” includes an informal agreement or a plan,...

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Words and Phrases
arrangement event
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) having a Swiss/Lux subsidiary enter into long-term purchase contracts at a somewhat fixed price with third parties and the taxpayer did not engage s. 247(2) 708
Tax Topics - General Concepts - Sham transactions that were not factually misrepresented were not a sham 254
Tax Topics - Income Tax Act - Section 248 - Subsection 248(10) "series" concept narrowly interpreted to permit comparison with arm's length transactions 40

10 October 2014 APFF Roundtable Q. 19, 2014-0538041C6 F - 2014 APFF Roundtable, Q. 19 - Stock dividend

purpose test in Reg. 6205(2)(a) is not necessarily accomplished by all estate freezes/"arrangement" broad

Mr. X holds all 100 of Opco's Class A shares with a fair market value of $1,000,000 and nominal ACB and PUC. Opco pays a stock dividend comprising...

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Words and Phrases
arrangement
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1.1) not engaged if stock dividend is proportional 211
Tax Topics - Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) SI apportionment to stock dividend prefs 251
Tax Topics - Income Tax Act - Section 74.4 - Subsection 74.4(2) non-application to stock dividend, cf. s. 86 reorg 255

30 September 1992 T.I. (Tax Window, No. 24, p. 18, ¶2180)

The word "arrangement" is open to very broad interpretation ranging from formal contracts to verbal understandings. S.96(2.4)(d) can apply where a...

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Words and Phrases
arrangement

Re Assaly and Minister of Revenue (1986), 56 OR (2d) 30 (HCJ)

value of consideration included obligation of purchaser to pay for vendor's subsequent construction of condos

A corporation owned by the appellant entered into an agreement with him in 1981 to sell vacant land to him for a purchase price of $185,000 with...

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Words and Phrases
relating to arrangement

Newton v. Commissioner of Taxation of the Commonwealth of Australia, [1958] A.C. 450 (PC)

Before finding that dividend stripping transactions were void for taxation purposes by virtue of s. 260 of the Commonwealth Income Tax and Social...

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Words and Phrases
arrangement
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) 51

Apple Fields Ltd. v. New Zealand Apple and Pear Marketing Board, [1991] 2 WLR 129 (PC)

S.27(1) of the Commerce Act 1986 (New Zealand) provided:

"No person shall enter into a contract or arrangement, or arrive at an understanding,...

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Words and Phrases
arrangement

Deckelbaum v. MNR, 82 DTC 1636, [1982] CTC 2659 (T.R.B.)

A home purchase loan arrangement was evidenced by a resolution of the corporation authorizing the making of the loan and providing for its...

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Words and Phrases
arrangement

Davidson v. The Queen, 99 DTC 933, [1999] 3 CTC 2159 (TCC)

Before finding that a loan made by a family company to the taxpayer to finance the acquisition of a home satisfied the requirements for bona fide...

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Words and Phrases
arrangement
Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence 39