Words and Phrases - "group"
Canada v. Deans Knight Income Corporation, 2021 FCA 160, aff'd 2023 SCC 16
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...
Words and Phrases
group| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | avoidance of a de jure acquisition of a Lossco through acquiring “actual control” was abusive | 591 |
Vina-Rug (Canada) Limited v. Minister of National Revenue, 68 DTC 5021, [1968] CTC 1, [1968] S.C.R. 193
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...
Atomic Truck Cartage Ltd. v. The Queen, 86 DTC 6032, [1985] 2 CTC 21, [1985] DTC 5427 (FCTD)
The phrase "group of persons" in s.251(4)(a) refers to a group of two or more persons.
Words and Phrases
group| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 256 - Subsection 256(1) - Paragraph 256(1)(e) | 123 |
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 CorporationU.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...
Words and Phrases
group| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 256 - Subsection 256(5.1) | must be right to affect board or directly influence shareholders | 187 |
| Tax Topics - Income Tax Act - Section 256 - Subsection 256(6) | 65 | |
| Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. | 23 | |
| Tax Topics - Statutory Interpretation - Interpretation Act - Subsection 45(2) | 56 | |
| Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc. | 64 |