Articles

About Articles The articles below are published by the Taxation Law Section of the Ontario Bar Association. Members are encouraged to submit articles. About Articles

Editor: Darren Joblonkay

Today
Today

An Update on Non-Qualifying Amalgamations After Envision

  • November 01, 2011
  • Mark Tozer

An amalgamation is defined for the purposes of subsection 87(1) as a merger of taxable Canadian corporations where all of the property, liabilities and shareholders of the predecessor corporations immediately...

Peter Sommerer v. The Queen: the Tangled Web of subsection 75(2) Unravelled

  • November 01, 2011
  • Michele Anderson

The recent decision in Sommerer v. The Queen, in particular, the interpretation of subsection 75(2) and whether it applied in the context of a fair market value sale of shares by the Appellant, one of the beneficiaries of an Austrian private foundation, to the foundation.