Lee v. The Queen, 2018 TCC 230
| Jurisdiction | Federal Jurisdiction (Canada) |
| Court | Tax Court (Canada) |
| Citation | 2018 TCC 230 |
| Date | 15 November 2018 |
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4 practice notes
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Grenon v. The Queen, 2021 TCC 30
...on real steps being taken in respect of actual entities” [53] . In this respect, the Appellant relies on Lee v The Queen, 2018 TCC 230 (“Lee”), where Owen J. stated that “[c]reating legal (or equitable) relationships to give effect to a tax plan is not the perpet......
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Husky Energy Inc. v. The King, 2023 TCC 167
...Federal Court of Appeal in 2009 FCA 57 at paragraph 16(c). [213] I explained the meaning of “legal substance” in Lee v. R., 2018 TCC 230 at paragraph 52 and footnote [214] See Timothy R. Hughes, Income Tax Implications of the Non-Dispositive Transfer of Equity Securities, (199......
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From Transfer Pricing To Tax Treaties: Canadian Cross-Border Tax Update
...described by those contracts. This case, along with another recent Tax Court of Canada decision, Van Lee v her Majesty the Queen, 2018 TCC 230 (also argued by Osler), confirms that Canadian courts will continue to apply the sham doctrine sparingly in tax cases, reserving it for instances wh......
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Ain't That A Shame - That Ain't A Sham
...execution should not be overwhelmed by unsupported assertions that tax planning is naughty, thus a sham. Footnotes [1] 2018 TCC 195. [2] 2018 TCC 230 [3] [1967] 1 All E.R. 518 ("Snook"). [4] [1984] 1 S.C.R. 536 ("Stubart"). [5] {1987] 1 SCR 32. [6] 2009 TCC 465 ("Antle") (aff'd on this poin......
1 cases
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Husky Energy Inc. v. The King, 2023 TCC 167
...Federal Court of Appeal in 2009 FCA 57 at paragraph 16(c). [213] I explained the meaning of “legal substance” in Lee v. R., 2018 TCC 230 at paragraph 52 and footnote [214] See Timothy R. Hughes, Income Tax Implications of the Non-Dispositive Transfer of Equity Securities, (199......
2 firm's commentaries
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From Transfer Pricing To Tax Treaties: Canadian Cross-Border Tax Update
...described by those contracts. This case, along with another recent Tax Court of Canada decision, Van Lee v her Majesty the Queen, 2018 TCC 230 (also argued by Osler), confirms that Canadian courts will continue to apply the sham doctrine sparingly in tax cases, reserving it for instances wh......
-
Ain't That A Shame - That Ain't A Sham
...execution should not be overwhelmed by unsupported assertions that tax planning is naughty, thus a sham. Footnotes [1] 2018 TCC 195. [2] 2018 TCC 230 [3] [1967] 1 All E.R. 518 ("Snook"). [4] [1984] 1 S.C.R. 536 ("Stubart"). [5] {1987] 1 SCR 32. [6] 2009 TCC 465 ("Antle") (aff'd on this poin......