Words and Phrases - "one of the main purposes"

a
89
b
44
c
86
d
56
e
43
f
31
g
20
h
15
i
77
j
2
k
2
l
32
m
57
n
29
o
40
p
82
q
3
r
78
s
95
t
47
u
16
v
10
w
23
y
2

May 2016 Alberta CPA Roundtable, Income Tax Q.9

Summary Under
Tax Topics - Income Tax Act - Section 74.4 - Subsection 74.4(2)
“one of the main purposes” in s. 74.4(2) re freeze trust with minor child acquiring common shares

When asked to comment on factors taken into account in deciding if “one of the main purposes” of a transfer or loan is reasonably considered...

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Words and Phrases
one of the main purposes

Groupe Honco Inc. v. Canada, 2014 DTC 5006, 2013 FCA 128, aff'g 2013 DTC 1032 [at 149], 2012 TCC 305, infra

Summary Under
Tax Topics - Income Tax Act - Section 83 - Subsection 83(2.1)
two or three main purposes

Trudel JA stated (at para. 24) that:

[C]ounsel for the appellants is ignoring the purpose and spirit of subsection 83(2.1) of the Act in...

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Words and Phrases
one of the main purposes