Simon's Legal Resources

(Ontario/Canada)

EVIDENCE | ADMINISTRATIVE LAW | SPPA / Fairness (Administrative)
SMALL CLAIMS / CIVIL LITIGATION / CIVIL APPEALS / JUDICIAL REVIEW / Something Big

Home / About / Democracy, Law and Duty / Testimonials / Conditions of Use

Civil and Administrative
Litigation Opinions
for Self-Reppers


TOPICS

(What's a Topic?)

Federal Tax - Tax Shelter

. Krumm v. Canada

In Krumm v. Canada (Fed CA, 2021) the Federal Court of Appeal sets out the ITA definition of a 'tax shelter':
[14] A tax shelter as defined in subsection 237.1(1) of the Act generally describes a property that is marketed on the basis that prospective purchasers could expect a specified after-tax result if they acquire an interest in the property. The relevant part of the definition applicable to the taxation years at issue reads: "“… it can reasonably be considered, having regard to statements or representations made or proposed to be made in connection with the property, that [within a four year period] … the total of all amounts each of which is … represented to be deductible … would equal or exceed [the cost of the property, as adjusted].”"

CC0

Unless authorship is otherwise stated or obvious from the context, all
written materials in this website were created by Simon Shields, who
waives all of his copyright and related or neighboring rights to this
Isthatlegal.ca webpage. Note in particular that this waiver only applies to
Simon's material, as copyright in statutory/regulatory materials and
case extracts were never his to give away.




Last modified: 23-04-21
By: admin