Unfortunately, taxpayers sometimes play fast and loose with the legalities surrounding family trusts. Sometimes trustees will purport to make distributions from a trust to its beneficiaries. The beneficiaries treat the amounts received as income for tax purposes, but then those…
Sham and Golini
On Golini v R, 2016 TCC 174, Karen Stilwell writes: With respect to the assignment by Holdco, however, the Court reached a different conclusion. It found that though the collateral assignment by Holdco to secure its guarantee presented itself as…