Deans Knight Income Corp. v. Canada,
| Jurisdiction | Federal Jurisdiction (Canada) |
| Judge | Wagner, Richard; Karakatsanis, Andromache; Côté, Suzanne; Brown, Russell; Rowe, Malcolm; Martin, Sheilah; Kasirer, Nicholas; Jamal, Mahmud; O’Bonsawin, Michelle |
| Docket Number | 39869 |
| Date | 26 May 2023 |
| Court | Supreme Court (Canada) |
| Citation | 2023 SCC 16 |
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23 practice notes
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Deans Knight Income Corporation v Canada,
...Attorney General of Ontario, Canadian Chamber of Commerce, Tax Executives Institute, Inc., and Agence du Revenu du Québec Interveners 2023 SCC 16 Present: Wagner C.J. and Karakatsanis, Côté, Brown, * Rowe, Martin, Kasirer, Jamal and O'Bonsawin JJ. DOCKET: 39869 SUPREME C......
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Magren Holdings Ltd v. Canada,
...Copthorne Holdings Ltd. v. Canada, 2011 SCC 63 , [2011] 3 S.C.R. 721 at para. 33 [Copthorne]; Deans Knight Income Corp. v. Canada, 2023 SCC 16, [2023] 4 C.T.C. 25 at para. 51 [Deans [176] While “tax benefit” and “avoidance transaction” are defined in the Income Tax Act , to determine ......
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3295940 Canada Inc. v. Canada,
...at issue. This first stage is a question of law, subject to correctness review by appellate courts: Deans Knight Income Corp. v. Canada, 2023 SCC 16 at para. 78 [Deans Knight]; Canada v. Alta Energy Luxembourg S.A.R.L., 2021 SCC 49 at para. 50; Canada Trustco Mortgage Co. v. Canada, 2005 SC......
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Madison Pacific Properties Inc. v. The King,
...SCC 63 , at para. 33; Canada Trustco Mortgage Co. v. The Queen, 2005 SCC 54 , at para. 17; Deans Knight Income Corp. v. The King, 2023 SCC 16. [2] After the share exchange described below, Shanoro held 167,500 Class B voting shares of the Appellant. Those shares were obtained on a sha......
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13 cases
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Deans Knight Income Corporation v Canada,
...Attorney General of Ontario, Canadian Chamber of Commerce, Tax Executives Institute, Inc., and Agence du Revenu du Québec Interveners 2023 SCC 16 Present: Wagner C.J. and Karakatsanis, Côté, Brown, * Rowe, Martin, Kasirer, Jamal and O'Bonsawin JJ. DOCKET: 39869 SUPREME C......
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Magren Holdings Ltd v. Canada,
...Copthorne Holdings Ltd. v. Canada, 2011 SCC 63 , [2011] 3 S.C.R. 721 at para. 33 [Copthorne]; Deans Knight Income Corp. v. Canada, 2023 SCC 16, [2023] 4 C.T.C. 25 at para. 51 [Deans [176] While “tax benefit” and “avoidance transaction” are defined in the Income Tax Act , to determine ......
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3295940 Canada Inc. v. Canada,
...at issue. This first stage is a question of law, subject to correctness review by appellate courts: Deans Knight Income Corp. v. Canada, 2023 SCC 16 at para. 78 [Deans Knight]; Canada v. Alta Energy Luxembourg S.A.R.L., 2021 SCC 49 at para. 50; Canada Trustco Mortgage Co. v. Canada, 2005 SC......
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Madison Pacific Properties Inc. v. The King,
...SCC 63 , at para. 33; Canada Trustco Mortgage Co. v. The Queen, 2005 SCC 54 , at para. 17; Deans Knight Income Corp. v. The King, 2023 SCC 16. [2] After the share exchange described below, Shanoro held 167,500 Class B voting shares of the Appellant. Those shares were obtained on a sha......
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9 firm's commentaries
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Deans Knight: The Case For Rethinking GAAR Amendments
...On May 26, 2023, the Supreme Court of Canada (SCC or the Court) dismissed the taxpayer's appeal in Deans Knight Income Corp. v Canada, 2023 SCC 16 (Deans Knight). This much-anticipated decision deals with the general anti-avoidance rule (GAAR) in section 245 of the Income Tax Act2 (Act). Wh......
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Deans Knight Will Have A Serious Impact On Tax Planning & Tax Disputes
...fulfill our "thriving Canada" shared goal? And please show your work for clarity. Footnotes 1. Deans Knight Canada Income Corp. v. Canada, 2023 SCC 16. 2. Ibid at 3. Ibid at 95. 4. Ibid at 113. 5. Ibid at 151. 6. Ibid at 146. 7. Ibid at 150. 8. Ibid at 151. 9. Ibid at 143. 10. While this mi......
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Supreme Court Of Canada Issues Much-anticipated Decision On GAAR
...26, 2023, the Supreme Court of Canada (SCC or the Supreme Court) dismissed the taxpayer's appeal in Deans Knight Income Corp. v Canada, 2023 SCC 16 (Deans Knight). This much-anticipated decision deals with the general anti-avoidance rule (GAAR) in section 245 of the Income Tax Act1 (Act). T......
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Episode 029 ' The Supreme Court Of Canada's Decision Of Deans Knight: Decoding The Tax Implications (Podcast)
...Deans Knight. On May 26, 2023, the Supreme Court of Canada released its landmark decision in Deans Knight Income Corp. v. Canada cited as 2023 SCC 16. The case involved whether the application of the general anti-avoidance rule ("GAAR") applied to deny a loss-utilization plan by the taxpaye......
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