Words and Phrases - "particular"
Perfect Fry Company Ltd. v. The Queen, 2007 DTC 588, 2007 TCC 133, aff'd supra 2008 DTC 6472, 2008 FCA 218
Paris J. found (at p. 600) that paragraph (b) of the definition "was not intended to require an attribution of the ownership of shares of a corporation to a hypothetical shareholder in the case where all of the shares of the corporation are already owned by a single shareholder". Accordingly, paragraph (b) did not apply to a wholly-owned subsidiary of a public corporation whose ultimate control was by a group of Canadian resident individuals.
Words and Phrases
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Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(c) | 92 |