series of transactions or events

454538 Ontario Ltd. v. MNR, 93 DTC 427, [1993] 1 CTC 2746 (TCC) -- summary under Subsection 55(2)

Full Title
454538 Ontario Ltd. v. MNR, 93 DTC 427, [1993] 1 CTC 2746 (TCC)
Summary Under
Tax Topics - Income Tax Act - Section 55 - Subsection 55(2)

Two brothers (the "Mazzoccas"), who constituted two of the three equal shareholders of a corporation ("Tri-M"), transferred their shares of Tri-M...

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series of transactions or events
income

Toronto-Dominion Bank v. Canada, 2011 DTC 5125 [at at 6061], 2011 FCA 221, [2011] 6 CTC 19 -- summary under Subsection 248(10)

Full Title
Toronto-Dominion Bank v. Canada, 2011 DTC 5125 [at at 6061], 2011 FCA 221, [2011] 6 CTC 19
Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(10)
"series of transactions" must be pre-ordained absent s. 248(10)

A transitional provision in the Act provided that the old s. 55(1) would apply to a transaction if it were "part of a series of transactions,...

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series of transactions or events

Meeuse v. The Queen, 94 DTC 1397 (TCC) -- summary under Subsection 15(2.6)

Full Title
Meeuse v. The Queen, 94 DTC 1397 (TCC)
Summary Under
Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.6)
purpose of avoiding disguised corporate distribution

Each of the loans made to the taxpayer by her husband's company were for separate purposes, for example, financing her acquisition of an...

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Words and Phrases
series of transactions or events
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