Words and Phrases - "event"

a
86
b
44
c
76
d
50
e
38
f
31
g
18
h
14
i
73
j
2
k
2
l
32
m
56
n
25
o
38
p
80
q
3
r
76
s
89
t
46
u
15
v
9
w
23
y
2

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, whether legally enforceable or not,[Fn. 779: Davidson v. R., [1999] 3 C.T.C 2159 at paragraph 14 and the dissenting judgment of Spence J. in Geophysical Engineering Ltd. v. M.N.R., [1977] 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, [1958] 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.]

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 82