Précis: The appellant received payments in 2004, 2005 and 2006 from its foreign affiliates. The payments were described as dividends. Subsequently the appellant obtained rectification orders in Cyprus and Barbados declaring such payments not to be dividends but rather transfers that resulted in indebtedness by the appellant to the foreign affiliates in the amount of the transfers. The appellant applied for an order under section 58 of the Tax Court of Canada Rules (General Procedure) that a question of law be determined before the hearing:
Canadian Forest Navigation v. R. - FCA: Effect of foreign court orders sent back to Tax Court as issue of factREAD MORE »