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 |
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 |
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 satisfied share purchase consideration | 114 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) | a single payment can result in income inclusions to 2 taxpayers - the 2nd as a taxable benefit | 91 |
| 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...