In the case of Fundy Settlement v. Canada, the Supreme Court of Canada decided that two trusts were considered residents of Canada for tax purposes because their main business decisions were made by beneficiaries living in Canada, even though the…
Introduction The Supreme Court of Canada's ruling in Deans Knight Income Corporation v. Her Majesty the Queen represents a landmark decision in the context of Canadian tax law, particularly relevant to high-net-worth individuals and family-owned enterprises. This decision meticulously analyzes…
The Commissioners of Inland Revenue v. His Grace The Duke of Westminster is a 1936 case that has become infamous for the orbiter often quoted from the appeal court justice Lord Tomlin who famously said “every man is entitled, if…
It used to be simple to move a dividend from a subsidiary to its parent corporation. If the parent owned more than 10% of the shares, this would have no tax implication and no Part IV tax. However, the simple…