Words and Phrases - "arrangement"

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Canada v. Canadian Pacific Ltd., 2002 DTC 6742, [2002] 3 F.C. 170

an aspect of a transaction is not a transaction

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Words and Phrases
transaction arrangement
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) primary purpose of a borrowing in a tax-advantageous currency was to raise money 286
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) transaction not to be recharacterized until after a determination of abuse 275

5 October 2012 Roundtable, 2012-0454021C6 F - Expiration d'un arrangement

purpose of Reg. 6205(2) re estate freezes and employees

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Words and Phrases
arrangement

Cameco Corporation v. The Queen, 2018 TCC 195

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Words and Phrases
arrangement event
Locations of other summaries Wordcount
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) 686
Tax Topics - General Concepts - Sham transactions that were not factually misrepresented were not a sham 246
Tax Topics - Income Tax Act - Section 248 - Subsection 248(10) "series" concept narrowly interpreted to permit comparison with arm's length transactions 38

10 October 2014 APFF Roundtable Q. 19, 2014-0538041C6 F - 2014 APFF Roundtable, Q. 19 - Stock dividend

purpose test in Reg. 6205(2)(a) is not necessarily accomplished by all estate freezes/"arrangement" broad

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Words and Phrases
arrangement
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1.1) not engaged if stock dividend is proportional 203
Tax Topics - Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) SI apportionment to stock dividend prefs 245
Tax Topics - Income Tax Act - Section 74.4 - Subsection 74.4(2) non-application to stock dividend, cf. s. 86 reorg 243

30 September 1992 T.I. (Tax Window, No. 24, p. 18, ΒΆ2180)

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Words and Phrases
arrangement

Re Assaly and Minister of Revenue (1986), 56 OR (2d) 30 (HCJ)

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Words and Phrases
relating to arrangement

Newton v. Commissioner of Taxation of the Commonwealth of Australia, [1958] A.C. 450 (PC)

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Words and Phrases
arrangement
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) 43

Apple Fields Ltd. v. New Zealand Apple and Pear Marketing Board, [1991] 2 WLR 129 (PC)

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Words and Phrases
arrangement

Deckelbaum v. MNR, 82 DTC 1636 (T.R.B.)

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Words and Phrases
arrangement

Davidson v. The Queen, 99 DTC 933 (TCC)

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Words and Phrases
arrangement
Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence 37