Words and Phrases - "sham"

a
82
b
44
c
75
d
50
e
37
f
31
g
17
h
13
i
71
j
2
k
2
l
30
m
51
n
25
o
38
p
79
q
2
r
73
s
85
t
44
u
14
v
8
w
20
y
2
“
1

Chad v. The Queen, 2022 TCC 18

Summary Under
Tax Topics - General Concepts - Window Dressing
sham is deceitful misrepresentation of a transaction’s nature, whereas window dressing is deceptively making the facts look better

Before denying a motion of the Crown to add an allegation of “window dressing” in its pleadings, Sommerfeldt J stated (footnote 39).

It is my...

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Words and Phrases
sham window dressing
Locations of other summaries Wordcount
Tax Topics - Other Legislation/Constitution - Federal - Tax Court of Canada Rules (General Procedure) - Section 54 the Crown could not resile from an oral representation that it would not argue “tax shelter” at trial 506

28 October 2010 Internal T.I. 2010-0376041I7 F - Contrat d'acquisition ou de location

Summary Under
Tax Topics - General Concepts - Substance
contracts (e.g., leases) generally not recharacterized in the absence of sham

Motor vehicle lease agreements between a company and a leasing company provide that the company will automatically acquire ownership of the leased...

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Words and Phrases
sham
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 6 - Subsection 6(2) - Element E lease where lessee got benefits of ownership even if it didn’t acquire title needed study to determine its true nature 171
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A lease where lessee got benefits of ownership even if it didn’t acquire title not necessarily a lease 135