Words and Phrases - "one of the main reasons"

a
88
b
44
c
80
d
53
e
38
f
31
g
19
h
14
i
74
j
2
k
2
l
32
m
56
n
25
o
38
p
81
q
3
r
77
s
90
t
47
u
16
v
9
w
23
y
2

24 August 2023 Internal T.I. 2019-0810391I7 - Offshore Investment Fund Property:

Summary Under
Tax Topics - Income Tax Act - Section 94.1 - Subsection 94.1(1)
Gerbro and earlier positions on "portfolio investment" applied/ nature of "one of the main reasons" test

What is a “portfolio investment” as used in s. 94.1(1)(b)?

After referring to earlier positions and Gerbro as to the meaning of "portfolio...

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Words and Phrases
one of the main reasons

Prairielane Holdings Ltd. v. The Queen, 2019 TCC 157

Summary Under
Tax Topics - Income Tax Act - Section 256 - Subsection 256(2.1)
a “main reason” for a stacked partnership structure was deferral rather than generating SBD tax savings

The two taxpayers (“PLH” and “SCL”), which were each controlled by two unrelated individuals, would have been associated with each other...

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Words and Phrases
one of the main reasons