Words and Phrases - "group"

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Canada v. Deans Knight Income Corporation, 2021 FCA 160, leave granted 10 March 2022

the object and spirit of s. 111(5) is abused on an arm’s length acquisition of “actual” (albeit, not de jure) control of a Lossco

The non-capital losses of $90M, and other tax attributes of the taxpayer, were effectively sold to arm’s length investors pursuant to...

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Words and Phrases
group
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) avoidance of a de jure acquisition of a Lossco through acquiring “actual control” was abusive 591

Vina-Rug (Canada) Limited v. Minister of National Revenue, 68 DTC 5021, [1968] CTC 1, [1968] 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...

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Words and Phrases
group of persons group

Atomic Truck Cartage Ltd. v. The Queen, [1985] 2 CTC 21, 86 DTC 6032 (FCTD)

The phrase "group of persons" in s.251(4)(a) refers to a group of two or more persons.

Words and Phrases
group

Silicon Graphics Ltd. v. Canada, 2002 DTC 7113, 2002 FCA 260

U.S. public shareholders not a group; no de facto control by lender/licensor

The taxpayer, which was a Canadian corporation with Canadian management, had effected a public offering of its common shares in the U.S. as a...

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Words and Phrases
group