Words and Phrases - "event"

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

Cameco Corporation v. The Queen, 2018 TCC 195, aff'd 2020 FCA 112

Summary Under
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(1) - Transaction
meaning of "arrangement" and "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,...

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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) 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