See Also
Mingle v. The Queen, 2022 TCC 34
Wong J rejected the taxpayer’s submissions that he had renounced his executorship shortly after being appointed and that his subsequent acts in...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 159 - Subsection 159(3) | even if the taxpayer had renounced his executorship, his acting as a trustee de son tort would have rendered him liable under s. 159(3) | 290 |
| Tax Topics - Income Tax Act - Section 222 - Subsection 222(5) - Paragraph 222(5)(c) | assessment of executor under s. 159(3) within the s. 222(4) 10-year period restarted the limitation period pursuant to s. 222(5)(c) | 63 |
Groscki v. The Queen, 2017 TCC 249 (Informal Procedure)
Bocock J found that a director was not a “legal representative” of a Macao-incorporated corporation that disposed of all of its inventory...
| 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 | 328 |
| 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 | 316 |
Administrative Policy
11 January 2002 External T.I. 2001-0112605 F - Section 159 - Payments on behalf of others159(2)
The arm’s length purchaser of a building paid the purchase price to a notary who, acting on its instructions, used a portion to discharge the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 159 - Subsection 159(2) | payment of purchase price by purchaser to trust account of its lawyer or purchaser’s lawyer for discharge first of non-CCRA debts did not engage s. 159(2) | 192 |