Words and Phrases - "event"
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, whether legally enforceable or not,[Fn. 779: Davidson v. R.,  3 C.T.C 2159 at paragraph 14 and the dissenting judgment of Spence J. in Geophysical Engineering Ltd. v. M.N.R.,  2 S.C.R. 1008 at pages 1023 and 1024, in both of which the decision of the Judicial Committee of the Privy Council in Newton v. Commissioner of Taxation of the Commonwealth of Australia,  2 All E.R. 759 (P.C.) at page 763 is cited.] ... and an “event” includes “anything that happens”. [Fn. 780: The OED defines the noun “event” as “[t]he (actual or contemplated) fact of anything happening” and “[a]nything that happens, or is contemplated as happening”. However, the statutory context requires that this definition be limited to anything that in fact happens.]
|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)||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||40|