group

Full Title

Canada v. Deans Knight Income Corporation, 2021 FCA 160, aff'd 2023 SCC 16

Summary Under

the object and spirit of s. 111(5) is abused on an arm’s length acquisition of “actual” (albeit, not de jure) control of a Lossco

The non-capital losses of $90M, and other tax attributes of the taxpayer, were effectively sold to arm’s length investors pursuant to...

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Words and Phrases

Full Title

Vina-Rug (Canada) Limited v. Minister of National Revenue, 68 DTC 5021, [1968] CTC 1, [1968] S.C.R. 193

Summary Under

Because John Stradwick, Jr., his brother W.L. Stradwick and H.D. McGilvery, who collectively owned more than 50% of the shares of Stradwick's and...

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Words and Phrases

Full Title

Atomic Truck Cartage Ltd. v. The Queen, 86 DTC 6032, [1985] 2 CTC 21, [1985] DTC 5427 (FCTD)

Summary Under

The phrase "group of persons" in s.251(4)(a) refers to a group of two or more persons.

Words and Phrases

Full Title

Silicon Graphics Ltd. v. Canada, 2002 DTC 7113, 2002 FCA 260

Summary Under

U.S. public shareholders not a group; no de facto control by lender/licensor

The taxpayer, which was a Canadian corporation with Canadian management, had effected a public offering of its common shares in the U.S. as a...

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Words and Phrases

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