Words and Phrases - "transfer"
Barwicz v. The King, 2024 CCI 93
The taxpayer was one of nine beneficiaries of a discretionary inter vivos personal trust which ceased to be resident in Canada in 2001. In January...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(4) - Paragraph 128.1(4)(b) | s. 128.1(4)(a) applied for s. 94 purposes | 286 |
| Tax Topics - Income Tax Act - Section 94 - Subsection 94(3) - Paragraph 94(3)(a) | s. 94(1)(c) did not change the shortened taxation year arising under s. 128.1(4)(a) | 229 |
| Tax Topics - General Concepts - Fair Market Value - Other | capital interest in discretionary personal trust had nil value | 157 |
30 October 2002 Internal T.I. 2002-0134077 F - ATTRIBUTION DES GAINS EN CAPITAL
Two individuals transferred the shares they held of a particular company to their respective holding companies which, in turn, each disposed of a...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 74.5 - Subsection 74.5(6) | presence of indirect transfer through Holdcos for s. 74.5(1) purposes reinforced by s. 74.5(6) | 103 |
White v. The Queen, 2020 TCC 22
The taxpayer’s husband (Mr. White), who had previously been assessed as director of a defunct company for unremitted net GST and source...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 160 - Subsection 160(1) | deposit by spouse to joint bank account with the taxpayer was not a transfer to her | 145 |
2 November 2015 External T.I. 2014-0558991E5 F - Loan from an Amateur Athlete Trust
Must an athlete, who was deemed to be a beneficiary of an amateur athlete trust which granted loans for the purchase of a home, include the loan...
Kvas v. The Queen, 2016 TCC 199
The general contracting company (“CIA”) of two brothers was dissolved in January of 2008 (the “Dissolution Date”) for failure to file...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 84 - Subsection 84(2) | involuntary dissolution was not a s. 84(2) winding-up | 168 |
7 March 2016 External T.I. 2015-0608211E5 - Assignment of right to purchase
Would an assignment to a trust by a non-resident person of a right to purchase a Canadian apartment unit be considered a disposition of taxable...
The Queen v. Kieboom, 92 DTC 6382, [1992] 2 CTC 59 (FCA)
In finding that s. 74(1) applied to attribute dividend income to the taxpayer when he permitted his wife to subscribe for common shares of his...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) | 60 | |
| Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc. | 73 |
Delisle v. The Queen, 95 DTC 650 (TCC)
Funds that the taxpayer's son had transferred into a dormant bank account of the taxpayer were held by her as agent for her son, with the result...
Montreuil v. The Queen, 95 DTC 138 (TCC)
The appellant received a bequest under the will of his father, who died in the Cayman Islands while owing tax and interest to Revenue Canada. In...
Lemire v. The Queen, 2013 DTC 1065 [at at 346], 2012 TCC 367, aff'd 2014 DTC 5088 [at 7100], 2013 FCA 242
The taxpayer's common-law partner, in order to circumvent a hold on his account relating to personal financial difficulties, would have the...
Algoa Trust v. The Queen, 93 DTC 405, [1993] 1 CTC 2294 (TCC)
After finding that s. 160(1) applied to a cash dividend paid by a private corporation to its shareholder, Rip J. went on to find that s. 160(1)...
The Queen v. Paxton, 97 DTC 5012 (FCA)
After the taxpayer entered into an agreement for the sale of shares then owned by him to an arm's-length purchaser ("Tandet"), he took advantage...