Words and Phrases - "main reason"

a
85
b
44
c
75
d
50
e
38
f
31
g
18
h
14
i
72
j
2
k
2
l
32
m
54
n
25
o
38
p
79
q
3
r
76
s
88
t
46
u
15
v
9
w
22
y
2
“
1

S3-F2-C1 - Capital Dividends

Summary Under
Tax Topics - Income Tax Act - Section 83 - Subsection 83(2.1)

Main reason test

1.95 ... Groupe Honco...confirmed that a person can have more than one main reason for the acquisition of shares. If subsection...

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Words and Phrases
main reason
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 83 - Subsection 83(2) 258
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Shareholder 135
Tax Topics - Income Tax Act - Section 83 - Subsection 83(3) 57
Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (a) 739
Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (b) 142
Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (d) 773
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(z.1) 239
Tax Topics - Income Tax Act - Section 184 - Subsection 184(3) 322
Tax Topics - Income Tax Act - Section 83 - Subsection 83(2.2) 59
Tax Topics - Income Tax Act - Section 83 - Subsection 83(2.3) 53
Tax Topics - Income Tax Act - Section 83 - Subsection 83(2.4) 62
Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(b) - Subparagraph 53(1)(b)(ii) No denied increase where s. 55(2) applied to the s. 84(1) dividend 93
Tax Topics - Income Tax Act - Section 52 - Subsection 52(3) - Paragraph 52(3)(a) - Subparagraph 52(3)(a)(ii) No denied increase where s. 55(2) applied to the stock dividend 120
Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (a) - Subparagraph (a)(i) - Clause (a)(i)(C) 201

Gerbro Holdings Company v. Canada, 2016 TCC 173, briefly aff'd 2018 FCA 197

Summary Under
Tax Topics - Income Tax Act - Section 94.1 - Subsection 94.1(1)
offshore hedge fund investments were chosen in the main for commercial reasons (e.g., manager reputation), so that s. 94.1 did not apply

The taxpayer (“Gerbro”) was a Canadian investment corporation (owned by a family trust but with an elderly income beneficiary, so that Gerbro...

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Words and Phrases
portfolio investment main reason primarily
Locations of other summaries Wordcount
Tax Topics - General Concepts - Onus no taxpayer burden to displace assumptions of mixed fact and law 71
Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. Minister's statement was false 130
Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Rules (General Procedure) - Section 145 - Subsection 145(3) expert's report did not include all the underlying data 115