Words and Phrases - "transaction"
Canada v. Canadian Pacific Ltd., 2002 DTC 6742, [2002] 3 F.C. 170, 2002 FCA 98
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...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) | primary purpose of a borrowing in a tax-advantageous currency was to raise money | 290 |
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | transaction not to be recharacterized until after a determination of abuse | 283 |
Vocalspruce Ltd. v. Revenue and Customs Commissioners, [2014] BTC 50, [2014] EWCA Civ 1302 (English CA)
The parent company (Brixton plc) of the taxpayer (Vocalspruce) subscribed for zero coupon notes of group companies, and transferred the notes to...
R. v. Goldstein (1988), 42 C.C.C. (3d) 548 (Ont CA)
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...
MNR v. Granite Bay Timber Co. Ltd., 58 DTC 1066, [1958] CTC 117 (Ex Ct), briefly aff'd 59 DTC 1262 (SCC)
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....
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) | the shareholders had a common purpose in determining to wind-up the company | 223 |
Shaw-Almex Industries Limited v. The Queen, 2009 DTC 1377 [at 2080], 2009 TCC 538
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...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(b) - Subparagraph 152(4)(b)(iii) | 138 |
Ho v. The Queen, 2010 DTC 1214, 2010 TCC 325
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...