Words and Phrases - "trust"

a
85
b
44
c
76
d
50
e
38
f
31
g
18
h
14
i
72
j
2
k
2
l
32
m
55
n
25
o
38
p
79
q
3
r
76
s
89
t
46
u
15
v
9
w
22
y
2

Canada v. Canada North Group Inc., 2021 SCC 30, [2021] 2 S.C.R. 571

Summary Under
Tax Topics - General Concepts - Ownership
Crown deemed trust interest did not have the attributes of beneficial property ownership

The Crown challenged an order of the Alberta judge in CCAA proceedings regarding the Canada North group of companies that “priming charges”...

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Words and Phrases
beneficial ownership trust
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 227 - Subsection 227(4.1) a CCAA court can order a super-charge that has priority over the s. 227(4.1) deemed trust (which in fact does not create any Crown proprietary interest in the debtor’s assets) 841
Tax Topics - Statutory Interpretation - Interpretation/Definition Provisions detailed listing of items covered in the 2nd part of a means and includes definition had a limiting effect 289
Tax Topics - Statutory Interpretation - Interpretation Act - Section 8.1 Parliament chose to dissociate itself from provincial law in its drafting of a provision 229

Canada (Attorney General) v. British Columbia Investment Management Corp., 2019 SCC 63, [2019] 4 S.C.R. 559

Summary Under
Tax Topics - Statutory Interpretation - Interpretation Act - Section 8.1
“trust” interpreted in accordance with its common law meaning

BCI was a BC Crown agent which was formed to manage and hold investments for the provincial pension plans. The governing Act (the “PSPSA”) and...

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Words and Phrases
trust
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(1) statutory trust was not necessarily a “trust” 271
Tax Topics - Other Legislation/Constitution - Constitution Act, 1867 - Section 125 ETA taxes that would be borne by portfolio of which a Crown agent was legal owner would contravene s. 125 298
Tax Topics - Excise Tax Act - Section 122 s. 122 does not preclude imposition of collection duties 302

4 October 2010 Internal T.I. 2008-0289461I7 - Netherlands Antilles private foundation

Summary Under
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(1)
Netherlands Antilles private foundation qualifies as trust notwithstanding separate legal personality

A private foundation was created pursuant to the laws of the Netherlands Antilles and governed by Articles of Foundation. Its capital consists of...

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Words and Phrases
trust
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation Netherlands Antilles private foundation qualifies as a trust notwithstanding its separate legal personality 109