Deans Knight Income Corp. v. Canada, 2023 SCC 16
| 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 |
| Court | Supreme Court (Canada) |
| Date | 26 May 2023 |
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17 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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3295940 Canada Inc. v. Canada, 2024 FCA 42
...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, 2023 TCC 180
...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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Husky Energy Inc. v. The King, 2023 TCC 167
...these appeals. [293] On May 26, 2023, the Supreme Court of Canada released its judgment in Deans Knight Income Corp. v. Canada, 2023 SCC 16 (“Deans Knight”). Like in Lipson and Alta Energy, the issue in Deans Knight was the application of subsection 245(4) of the GAA......
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8 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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3295940 Canada Inc. v. Canada, 2024 FCA 42
...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, 2023 TCC 180
...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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Husky Energy Inc. v. The King, 2023 TCC 167
...these appeals. [293] On May 26, 2023, the Supreme Court of Canada released its judgment in Deans Knight Income Corp. v. Canada, 2023 SCC 16 (“Deans Knight”). Like in Lipson and Alta Energy, the issue in Deans Knight was the application of subsection 245(4) of the GAA......
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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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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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The General Anti-Avoidance Rule: Supreme Court Rules That Company Was Illegally Acquired For Tax Avoidance
...and interest may apply. Contact a lawyer at DSF today to discuss your tax planning needs. Footnotes 1. Deans Knight Income Corp. v Canada, 2023 SCC 16 at para 2 [DKIC v 2. Ibid at para 62. 3. Ibid at para 45. 4. Ibid at para 55. 5. Ibid at para 57. 6. Ibid at para 82. 7. Ibid at para 111. 8......
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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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