Words and Phrases - "group of persons"

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Promutuel Réassurance v. The Queen, 2020 TCC 13

27 insurance companies who acted in a cooperative manner were a “group of persons” for s. 256(7)(d) purposes

The taxpayer (“ProRé”) was a corporation without share capital engaged in the reinsurance of casualty risk whose capital had been contributed...

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Words and Phrases
group of persons
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 256 - Subsection 256(8.1) s. 256(8.1) deemed non-share insurance corporation to have issued shares to its insurance-company members 154

Yardley Plastics of Canada Ltd. v. MNR, 66 DTC 5183, [1966] CTC 215 (Ex Ct)

Two corporations whose voting shares were held as follows

Shareholder Canadian Moldings Yardley Plastics
Hill 4.6% 28%
Hill...

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Words and Phrases
group of persons

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

Birchcliff Energy Ltd. v. The Queen, 2015 TCC 232, nullified on procedural grounds 2017 FCA 89

grant of proxy did not detract from investors acting individually in own interest

A predecessor ("Birchcliff") of the taxpayer negotiated a plan to merge with a corporation ("Veracel"), which had discontinued its medical...

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Words and Phrases
group of persons
Locations of other summaries Wordcount
Tax Topics - General Concepts - Sham transitory share issuance under plan of arrangement was not a sham 177
Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) share subscription was avoidance transaction notwithstanding its "overarching purpose" was financing 148
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) abusive reverse takeover by Lossco through diverted private placement 261