Words and Phrases - "indirectly"
30 October 2002 Internal T.I. 2002-0134077 F - ATTRIBUTION DES GAINS EN CAPITAL
indirect transfer where individuals transfer shares to their Holdcos, who transfer such shares to the individuals’ respective spouses
Two individuals transferred the shares they held of a particular company to their respective holding companies which, in turn, each disposed of a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 74.5 - Subsection 74.5(6) | presence of indirect transfer through Holdcos for s. 74.5(1) purposes reinforced by s. 74.5(6) | 103 |
Canada v. 594710 British Columbia Ltd., 2018 FCA 166
stock dividend followed by redemption of the stock dividend shares effected in combination a transfer of property for no consideration
Income account treatment of the profits realized by a condo-project limited partnership was avoided through the corporate partners (the...
Words and Phrases
indirectly| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | allocation of most partnership profits to a lossco that acquired its interest at year end without economic risk was vacuous and abused ss. 96(1)(f), 103(1) and 160 | 634 |
| Tax Topics - Income Tax Act - Section 103 - Subsection 103(1) | s. 103(1) likely applies to the allocation of most of the partnership profits at year end to a lossco that never had significant economic interest or risk in the partnership business | 327 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(8) | s. 152(8) cured an error in an assessment as to when the taxation year in question commenced | 371 |
| Tax Topics - Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(f) | purpose of s. 96 is for income allocation to be allocated in accordance with economic participation | 102 |
Army & Navy Department Stores Ltd. v. Minister of National Revenue, 53 DTC 1185, [1953] CTC 293, [1953] 2 S.C.R. 496
Summary Under
Tax Topics - Income Tax Act - Section 251 - Subsection 251(2) - Paragraph 251(2)(c) - Subparagraph 251(2)(c)(i)shareholders do not indirectly own any of the corporation’s property
One-half of the shares of the 5,000 shares of the “Western Company” were owned by the “Alberta company,” and the other half were owned by...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Expressio Unius est Exclusio Alterius | reference to person implied exclusion of persons | 129 |
| Tax Topics - Statutory Interpretation - Interpretation Act - Subsection 33(2) | 129 | |
| Tax Topics - General Concepts - Ownership | the shares of a subsidiary of a corporation are not owned “indirectly” by the shareholders of that corporation | 134 |