transaction

Blackburn Radio Inc. v. The Queen, 2009 TCC 155 -- summary under Subparagraph 152(4)(b)(iii)

Full Title
Blackburn Radio Inc. v. The Queen, 2009 TCC 155
Summary Under
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(b) - Subparagraph 152(4)(b)(iii)
reference to transaction involving a non-resident does not include an arrangement or a series of transactions

Three relevant transactions or events took place in 1999.

The taxpayer decided that its wholly-owned US holding company would sell its shares of a...

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Words and Phrases
transaction

Canada v. Canadian Pacific Ltd., 2002 DTC 6742, [2002] 3 F.C. 170, 2002 FCA 98 -- summary under Transaction

Full Title
Canada v. Canadian Pacific Ltd., 2002 DTC 6742, [2002] 3 F.C. 170, 2002 FCA 98
Summary Under
Tax Topics - Income Tax Act - Section 245 - Subsection 245(1) - Transaction
an aspect of a transaction is not a transaction

The Crown argued that CP's act of denominating the debentures in Australian dollars was in and of itself a transaction and that it amounted to an...

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Words and Phrases
transaction
arrangement

Vocalspruce Ltd. v. Revenue and Customs Commissioners, [2014] BTC 50, [2014] EWCA Civ 1302 (English CA) -- summary under Interpretation/Definition Provisions

Full Title
Vocalspruce Ltd. v. Revenue and Customs Commissioners, [2014] BTC 50, [2014] EWCA Civ 1302 (English CA)
Summary Under
Tax Topics - Statutory Interpretation - Interpretation/Definition Provisions
must recognize concomitant consequences of deemed facts

The parent company (Brixton plc) of the taxpayer (Vocalspruce) subscribed for zero coupon notes of group companies, and transferred the notes to...

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Words and Phrases
transaction

MNR v. Granite Bay Timber Co. Ltd., 58 DTC 1066, [1958] CTC 117 (Ex Ct), briefly aff'd 59 DTC 1262 (SCC) -- summary under Transaction

Full Title
MNR v. Granite Bay Timber Co. Ltd., 58 DTC 1066, [1958] CTC 117 (Ex Ct), briefly aff'd 59 DTC 1262 (SCC)
Summary Under
Tax Topics - Income Tax Act - Section 245 - Subsection 245(1) - Transaction

In finding that a resolution of the shareholders to wind-up a company was a "transaction" for purposes of s. 8(3) of the 1948 Act, Thurlow J....

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Words and Phrases
transaction

R. v. Goldstein (1988), 42 C.C.C. (3d) 548 (Ont CA) -- summary under Transaction

Full Title
R. v. Goldstein (1988), 42 C.C.C. (3d) 548 (Ont CA)
Summary Under
Tax Topics - Income Tax Act - Section 245 - Subsection 245(1) - Transaction

With respect to the interpretation of s. 548(1) of the Criminal Code, Houlden J.A. stated (p. 557) "the words 'the same transaction', in my...

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Words and Phrases
same transaction
transaction

Shaw-Almex Industries Limited v. The Queen, 2009 DTC 1377 [at at 2080], 2009 TCC 538 -- summary under Capital Loss v. Loss

Full Title
Shaw-Almex Industries Limited v. The Queen, 2009 DTC 1377 [at at 2080], 2009 TCC 538
Summary Under
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss

The taxpayer obtained a guarantee of the obligations of a US-resident sister corporation ("Fusion") to a US bank for the purpose for the purpose...

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Words and Phrases
transaction

Ho v. The Queen, 2010 DTC 1214, 2010 TCC 325 -- summary under Subparagraph 152(4)(b)(iii)

Full Title
Ho v. The Queen, 2010 DTC 1214, 2010 TCC 325
Summary Under
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(b) - Subparagraph 152(4)(b)(iii)
"transaction" requires act

Webb, J. found that the Minister was not entitled to reassess the taxpayer on the basis that s. 75(2) imputed income of a family trust to the...

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Words and Phrases
transaction
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