Foreign Law

Table of Contents

Cases

Canada v. Loblaw Financial Holdings Inc., 2021 SCC 51

In finding that the business of a Barbados subsidiary of the taxpayer was not a “business conducted principally with persons with whom [it did]...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business “business conducted,” as contrasted to “business,” did not include the raising of capital 229
Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Investment Business - Paragraph (a) bank business was conducted with arm's length persons notwithstanding that capital raised from shareholder 579
Tax Topics - Statutory Interpretation - Certainty full effect should be given to Parliament’s precise and unequivocal words to produce certainty 88
Tax Topics - Statutory Interpretation - Speaking in vain Parliament does not speak in vain 72
Tax Topics - Income Tax Act - Section 91 - Subsection 91(1) two policies balanced in FAPI regime 79
Tax Topics - Statutory Interpretation - Expressio Unius est Exclusio Alterius specific addition of a competition requirement in another provision implied that there was no such requirement here 152

Administrative Policy

21 June 2016 Internal T.I. 2015-0581151I7 - Dutch Co-Op Entity Classification

Before going on to find that a Netherlands cooperative was a corporation for ITA purposes, the Directorate stated:

[T]he appropriate approach to...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation Dutch co-op a corporation 74
Tax Topics - Income Tax Act - Section 96 Dutch co-op a corp., not partnership 45

23 April 2013 Internal T.I. 2012-0466081I7 F - Usufruct created under French legislation

Before finding that a gift of real property subject to the reservation of a usufruct under French law was to be treated under ITA s. 43.1 in the...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 43.1 gift of immovable subject to reservation of a usufruct gave rise to a disposition under s. 43.1 282
Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b) disposition of all building under shared gift 277

24 March 2004 External T.I. 2003-0034311E5 - "liquidation and a dissolution": What does it mean

The Agency was advised that under the corporate law of the Czech Republic, there was a distinction between a wind-up with liquidation of a...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(e) process of distributing the assets and satisfying the liabilities is "liquidation" 275
Tax Topics - Statutory Interpretation - Provincial Law 70