Federal Court of Appeal Rules Paper Losses Cannot Offset Realized Capital Gains: 2763478 Canada Inc. v. Canada (2018 FCA 209) Category: Tax Case Summaries December 2, 2018 FACTS Jobin owned shares in Groupe AST (assume FMV = $13 million and ACB = $nil). He received an offer for his shares from Read More ITA Sections: 38, 38(1)(b), 38(c), 40, 40(1)(b) Topics: Estate Freeze, General anti-avoidance rule (GAAR), Loss Utilization, Stock Dividend, Stock Dividend Freeze
2763478 Canada Inc. v. Canada Category: Case Law (Tax Cases) November 30, 2018 2763478 Canada Inc. v. Canada Summary Click here for our summary of this case. Court (s) Database Federal Court of Appeal Decisions Date 2018-11-15 Read More ITA Sections: 38(1)(b), 38(b), 40(1)(b) Topics: Estate Freeze, General anti-avoidance rule (GAAR), Loss Utilization, Stock Dividend Freeze