Précis: The taxpayer received a dividend in the amount of $600,000 in 2006 from its subsidiary corporation, 0699406 B.C. Ltd. (“0699”). The Minister assessed the taxpayer under subsection 160(1) in respect of the non-arm’s length transfer. The taxpayer resisted the assessment both on the basis that the relationship with 0699 was at arm’s length and that it gave consideration for the dividend in the form of a loan back to 0699. The Tax Court rejected both arguments and dismissed the appeal with costs.
Gentile Holdings Ltd. v. R. – TCC: Dividends paid to taxpayer subject to a valid non-arm’s length assessment under subsection 160(1) of the ITAREAD MORE »