Legal Representative

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See Also

Groscki v. The Queen, 2017 TCC 249 (Informal Procedure)

director without liquidator authorization was not legal representative

Bocock J found that a director was not a “legal representative” of a Macao-incorporated corporation that disposed of all of its inventory (being substantially all of its assets) without CRA providing a s. 159(2) clearance certificate given that the director did not do a lot more than directors normally do and, in particular did not act as a liquidator given that there was no liquidation process authorized by the corporation nor any authority granted to him to act as a liquidator, de facto or otherwise.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 159 - Subsection 159(3) a director was not liable for failure to obtain a s. 159(2) certificate before his corporation disposed of most of its assets 298
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(ii) reporting of bad debt deduction on “net” basis not permitted/specifically-evidenced claims required 288

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