Category: 160 (page 2)

In White v R, 2020 TCC 22, the taxpayer’s husband owed tax debts under the Excise Tax Act at a time when he made deposits to their joint bank account. The issue was whether the taxpayer was liable under section…

In Eyeball Networks Inc. v R, 2019 TCC 150, the court held that section 160 applied to a transferee corporation (the new operating company or “TC”) that had received property from a distributing corporation (the old operating company or “DC”)…

In Monsell v R, 2019 TCC 5, the taxpayer received payments for no consideration from a corporation to which she was related. The CRA subsequently reassessed the corporation for additional taxes for a number of years and then assessed the…

In R v 594710 British Columbia Ltd., 2018 FCA 166, the Court held that GAAR applied to a complicated series of transactions in which profits of a limited partnership were allocated to a corporation with tax shelter where the economic…

Subsection 160(4) of the Income Tax Act (Canada) in effect provides an exception to the “long arm” of section 160 where at any time a taxpayer has transferred property to the taxpayer’s spouse or common-law partner pursuant to a decree,…

In Muir v R, 2020 TCC 8 (informal procedure), a corporation, after selling its dental practice, paid an amount to the controlling shareholder at a time when the corporation owed tax. The Court (Boyle J) found that (1) that the…