Words and Phrases - "group"
Vina-Rug (Canada) Limited v. Minister of National Revenue, 68 DTC 5021,  CTC 1,  S.C.R. 193
Because John Stradwick, Jr., his brother W.L. Stradwick and H.D. McGilvery, who collectively owned more than 50% of the shares of Stradwick's and Vina-Rug, had at all material times a sufficient interconnection as to be in a position to exercise control over the two corporations, and therefore constituted a 'group of persons' within the meaning of s. 39(4) of the pre-1972 Act, the two corporations were associated. It was irrelevant whether other combinations of majority shareholders could be found.
Atomic Truck Cartage Ltd. v. The Queen,  2 CTC 21 (FCTD)
The phrase "group of persons" in s.251(4)(a) refers to a group of two or more persons.
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|Tax Topics - Income Tax Act - Section 256 - Subsection 256(1) - Paragraph 256(1)(e)||79|