Words and Phrases - "group"

a
88
b
44
c
79
d
52
e
38
f
31
g
19
h
14
i
74
j
2
k
2
l
32
m
56
n
25
o
38
p
81
q
3
r
76
s
90
t
47
u
16
v
9
w
23
y
2

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

Summary Under
Tax Topics - Income Tax Act - Section 111 - Subsection 111(5) - Paragraph 111(5)(a)
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
group

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

Summary Under
Tax Topics - Income Tax Act - Section 256 - Subsection 256(1) - Paragraph 256(1)(b)

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
group of persons group

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

Summary Under
Tax Topics - Income Tax Act - Section 251 - Subsection 251(4) - Related Group

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

Words and Phrases
group

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

Summary Under
Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Canadian-Controlled Private Corporation
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
group