3295940 Canada Inc. v. Canada
| Jurisdiction | Federal Jurisdiction (Canada) |
| Citation | 2024 FCA 42 |
| Date | 07 March 2024 |
| Court | Court of Appeal (Canada) |
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4 practice notes
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Magren Holdings Ltd v. Canada
...November 2019); Univar Holdco Canada ULC v. Canada, 2017 FCA 207 , [2019] 2 F.C.R. 569 at paras. 19-20; 3295940 Canada Inc. v. Canada, 2024 FCA 42, [2024] 3 C.T.C. 93 at para. [200] While “in some instances, it may be that the existence of a tax benefit can only be established by compa......
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Wuswig Inc. v. The King, 2025 TCC 147
...Ibid, para 8. [237] Ibid, para 12. [238] Ibid, para 21. [239] Ibid, paras 22–23. [240] Ibid, para 25. [241] 3295940 Canada Inc v Canada, 2024 FCA 42 [3295940 Canada Inc]. [242] Appellant’s Supplementary Submissions, paras 20, [243] Ibid, para 26. [244] Ibid, para 27. [245] Ibid, para 30. [2......
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THE KING V QUEBECOR INC.
...Ltd. v. Canada, 2019 FCA 151 at paras. 27–28; Oxford Properties at paras. 106–110, 118–119; 3295940 Canada Inc. v. Canada, 2024 FCA 42 at para. [56] In this case, when the Court performs this task, it cannot accept the Crown’s arguments. It can, however, make two findings. (1) There was a t......
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Top 10 Need-To-Know Canadian Income Tax Cases From 2024
...Tétrault article. 2. No abusive tax avoidance where alternative transactions would have allowed similar tax results 3295940 Canada Inc., 2024 FCA 42 Miscau held shares of generic drug company (Opco) that was to be sold to a third party. Miscau held its share through the taxpayer (3295), a h......
2 cases
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Magren Holdings Ltd v. Canada,
...November 2019); Univar Holdco Canada ULC v. Canada, 2017 FCA 207 , [2019] 2 F.C.R. 569 at paras. 19-20; 3295940 Canada Inc. v. Canada, 2024 FCA 42, [2024] 3 C.T.C. 93 at para. [200] While “in some instances, it may be that the existence of a tax benefit can only be established by compa......
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Wuswig Inc. v. The King, 2025 TCC 147
...Ibid, para 8. [237] Ibid, para 12. [238] Ibid, para 21. [239] Ibid, paras 22–23. [240] Ibid, para 25. [241] 3295940 Canada Inc v Canada, 2024 FCA 42 [3295940 Canada Inc]. [242] Appellant’s Supplementary Submissions, paras 20, [243] Ibid, para 26. [244] Ibid, para 27. [245] Ibid, para 30. [2......
1 firm's commentaries
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Top 10 Need-To-Know Canadian Income Tax Cases From 2024
...Tétrault article. 2. No abusive tax avoidance where alternative transactions would have allowed similar tax results 3295940 Canada Inc., 2024 FCA 42 Miscau held shares of generic drug company (Opco) that was to be sold to a third party. Miscau held its share through the taxpayer (3295), a h......