Sheck v. The Queen, 2018 TCC 125
| Jurisdiction | Federal Jurisdiction (Canada) |
| Citation | 2018 TCC 125 |
| Court | Tax Court (Canada) |
| Date | 29 June 2018 |
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3 practice notes
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Colitto v. The Queen, 2019 TCC 88
...[42] White No.1, at para 18. [43] Filippazzo, at para 8. [44] Ibid, at para 14. [45] Ibid, at para 13. [46] Pliskow, at para 14. [47] 2018 TCC 125. [48] See Worrell, Kern and Walsh. [49] Assuming, of course, that the director cannot otherwise rely on any of subsections 227.1(2) to (5) to av......
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When Does Director's Liability Arise To Support Section 160 Assessment?
...Tax Court of Canada ("TCC") had considered these issues before, in cases including Filippazzo v R, 2000 DTC 2326 and Sheck v The Queen, 2018 TCC 125. 4. This limitation isolates the gratuitous portion of the transaction, and if the transferee pays FMV there is no third party liability expos......
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Cascading Derivative Assessments And Preconditions To Liability Under Sections 160 And 227.1 Of The Income Tax Act: Colitto v. Her Majesty The Queen, 2019 TCC 88
...source deductions (White v. R, 95 DTC 877, Filippazzo v. R, 2000 DTC 2326, Pliskow v. R, 2013 TCC 283, and Sheck v. The Queen (2018), 2018 TCC 125), the TCC in Colitto determined that this body of case law did not engage in a textual, contextual and purposive interpretation of how sections ......
1 cases
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Colitto v. The Queen, 2019 TCC 88
...[42] White No.1, at para 18. [43] Filippazzo, at para 8. [44] Ibid, at para 14. [45] Ibid, at para 13. [46] Pliskow, at para 14. [47] 2018 TCC 125. [48] See Worrell, Kern and Walsh. [49] Assuming, of course, that the director cannot otherwise rely on any of subsections 227.1(2) to (5) to av......
2 firm's commentaries
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When Does Director's Liability Arise To Support Section 160 Assessment?
...Tax Court of Canada ("TCC") had considered these issues before, in cases including Filippazzo v R, 2000 DTC 2326 and Sheck v The Queen, 2018 TCC 125. 4. This limitation isolates the gratuitous portion of the transaction, and if the transferee pays FMV there is no third party liability expos......
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Cascading Derivative Assessments And Preconditions To Liability Under Sections 160 And 227.1 Of The Income Tax Act: Colitto v. Her Majesty The Queen, 2019 TCC 88
...source deductions (White v. R, 95 DTC 877, Filippazzo v. R, 2000 DTC 2326, Pliskow v. R, 2013 TCC 283, and Sheck v. The Queen (2018), 2018 TCC 125), the TCC in Colitto determined that this body of case law did not engage in a textual, contextual and purposive interpretation of how sections ......