Eyeball Networks Inc. v. The Queen, 2019 TCC 150
| Jurisdiction | Federal Jurisdiction (Canada) |
| Court | Tax Court (Canada) |
| Citation | 2019 TCC 150 |
| Date | 18 July 2019 |
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2 practice notes
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EYEBALL NETWORKS INC. v. HER MAJESTY THE QUEEN, 2021 FCA 17
...THE QUEEN Respondent REASONS FOR JUDGMENT NOËL C.J. [1] This is an appeal from a decision of Bocock J. (the Tax Court judge), cited as 2019 TCC 150, confirming an assessment issued by the Minister of National Revenue (the Minister) under subsection 160(1) of the Income Tax Act, R.S.C., 1985......
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A Caution To Canadian Tax Planners: A Butterfly Reorganization Might Trigger Derivative Tax Liability Under Section 160 Of The Income Tax Act: Eyeball Networks Inc. v The Queen (2019 TCC 150) A Canadian Tax Lawyer's Analysis
...in consideration for that asset. We detail the mechanics of section 160 in the following section.) In Eyeball Networks Inc. v The Queen (2019 TCC 150), the Tax Court of Canada rendered a controversial decision, holding that section 160 applied to a setoff transaction occurring in the contex......
1 cases
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EYEBALL NETWORKS INC. v. HER MAJESTY THE QUEEN, 2021 FCA 17
...THE QUEEN Respondent REASONS FOR JUDGMENT NOËL C.J. [1] This is an appeal from a decision of Bocock J. (the Tax Court judge), cited as 2019 TCC 150, confirming an assessment issued by the Minister of National Revenue (the Minister) under subsection 160(1) of the Income Tax Act, R.S.C., 1985......
1 firm's commentaries
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A Caution To Canadian Tax Planners: A Butterfly Reorganization Might Trigger Derivative Tax Liability Under Section 160 Of The Income Tax Act: Eyeball Networks Inc. v The Queen (2019 TCC 150) A Canadian Tax Lawyer's Analysis
...in consideration for that asset. We detail the mechanics of section 160 in the following section.) In Eyeball Networks Inc. v The Queen (2019 TCC 150), the Tax Court of Canada rendered a controversial decision, holding that section 160 applied to a setoff transaction occurring in the contex......