Words and Phrases - "arrangement"
29 May 2008 External T.I. 2007-0262591E5 F - Remboursement de sommes versées par erreur
After disability payments to the taxpayer, under the policy taken out by the employer with an insurer, were suspended, then retroactively...
Canada v. Canadian Pacific Ltd., 2002 DTC 6742, [2002] 3 F.C. 170, 2002 FCA 98
The Crown argued that CP's act of denominating the debentures in Australian dollars was in and of itself a transaction and that it amounted to an...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) | primary purpose of a borrowing in a tax-advantageous currency was to raise money | 290 |
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | transaction not to be recharacterized until after a determination of abuse | 283 |
5 October 2012 Roundtable, 2012-0454021C6 F - Expiration d'un arrangement
An employee who subscribed directly for treasury shares, and subsequently transferred them to a new corporation could benefit from the Reg 6205(2)...
Cameco Corporation v. The Queen, 2018 TCC 195, aff'd 2020 FCA 112
As part of a preliminary discussion of s. 247(2), Owen J stated (at para. 677):
An “arrangement” includes an informal agreement or a plan,...
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| Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) | having a Swiss/Lux subsidiary enter into long-term purchase contracts at a somewhat fixed price with third parties and the taxpayer did not engage s. 247(2) | 708 |
| Tax Topics - General Concepts - Sham | transactions that were not factually misrepresented were not a sham | 254 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(10) | "series" concept narrowly interpreted to permit comparison with arm's length transactions | 84 |
10 October 2014 APFF Roundtable Q. 19, 2014-0538041C6 F - 2014 APFF Roundtable, Q. 19 - Stock dividend
Mr. X holds all 100 of Opco's Class A shares with a fair market value of $1,000,000 and nominal ACB and PUC. Opco pays a stock dividend comprising...
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| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1.1) | not engaged if stock dividend is proportional | 211 |
| Tax Topics - Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) | SI apportionment to stock dividend prefs | 251 |
| Tax Topics - Income Tax Act - Section 74.4 - Subsection 74.4(2) | non-application to stock dividend, cf. s. 86 reorg | 255 |
30 September 1992 T.I. (Tax Window, No. 24, p. 18, ¶2180)
The word "arrangement" is open to very broad interpretation ranging from formal contracts to verbal understandings. S.96(2.4)(d) can apply where a...
Re Assaly and Minister of Revenue (1986), 56 OR (2d) 30 (HCJ)
A corporation owned by the appellant entered into an agreement with him in 1981 to sell vacant land to him for a purchase price of $185,000 with...
Newton v. Commissioner of Taxation of the Commonwealth of Australia, [1958] A.C. 450 (PC)
Before finding that dividend stripping transactions were void for taxation purposes by virtue of s. 260 of the Commonwealth Income Tax and Social...
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| Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) | 51 |
Apple Fields Ltd. v. New Zealand Apple and Pear Marketing Board, [1991] 2 WLR 129 (PC)
S.27(1) of the Commerce Act 1986 (New Zealand) provided:
"No person shall enter into a contract or arrangement, or arrive at an understanding,...
Deckelbaum v. MNR, 82 DTC 1636, [1982] CTC 2659 (T.R.B.)
A home purchase loan arrangement was evidenced by a resolution of the corporation authorizing the making of the loan and providing for its...
Davidson v. R., 99 DTC 933, [1999] 3 CTC 2159 (TCC)
Before finding that a loan made by a family company to the taxpayer to finance the acquisition of a home satisfied the requirements for bona fide...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Evidence | 39 |