Words and Phrases - "winding-up"
Michael Kandev, Olivia Khazam, "Was there a ‘Liquidation and Dissolution’? A (Corporate) Existential Question", International Tax (Wolters Kluwer CCH), No. 118, June 2021, pp. 8-9
Commercial understanding of “liquidation” and “dissolution” (p. 8)
I]t is reasonably clear that the terms "liquidation" and "dissolution"...
Ian Bradley, Jonathan Bright, "The Stop-Loss Rules and Corporate Reorganizations – Interpretive Challenges", Canadian Tax Journal, (2019) 67:2, 383-410
Interpretation of "merger or combination" (pp. 391, 394, 396)
The CRA's interpretation of subparagraph 40(3.5)(c)(i) [in 2017-073715117] is based...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Interpretation Act - Subsection 33(2) | 126 |
Dauphin Plains Credit Union Ltd. v. Xyloid Industries Ltd., 80 DTC 6123, [1980] CTC 247, [1980] 1 S.C.R. 1182
The appellant was a secured debentureholder who, following default by the debtor (“Xyloid”), obtained a court order for the appointment of a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) | receiver-manager included | 25 |
| Tax Topics - Income Tax Act - Section 159 - Subsection 159(2) | 36 | |
| Tax Topics - Income Tax Act - Section 227 - Subsection 227(5) | 41 | |
| Tax Topics - Statutory Interpretation - Interpretation Act - Section 17 | 38 |
Kvas v. The Queen, 2016 TCC 199
The general contracting company (“CIA”) of two brothers was dissolved in January of 2008 (the “Dissolution Date”) for failure to file...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 160 - Subsection 160(1) | involuntary dissolution did not render the corporation a transferor | 195 |
Perrault v. The Queen, 78 DTC 6272, [1978] CTC 395 (FCA)
A substantial dividend was not paid on the "winding-up, discontinuance or reorganization" of a company's business because, following the payment...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | dividend satsified share purchase consideration | 114 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) | 32 | |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) | 48 |
Smythe et al. v. Minister of National Revenue, 69 DTC 5361, [1969] CTC 558, [1970] S.C.R. 64
The taxpayers were shareholders of a company (the "old company") who effectively converted its assets to cash through a series of transactions:...
Merritt v. MNR (1941), 2 DTC 513 (Ex Ct), rev'd [1942] S.C.R. 269, 2 DTC 561
The Premier Trust Company ("Premier") acquired all the shares of the taxpayer and other shareholders of the Security Loan and Savings Company...
Gilmour v. The Queen, 81 DTC 5322, [1981] CTC 401 (FCTD)
The taxpayer was the sole individual shareholder of a personal corporation ("LVG") which, in turn, owned approximately 1/3 of the common shares of...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | 99 |