Taxpayer successful on s. 160 assessment

In reaching the decision, the Tax Court of Canada considered whether the parties to the transaction attempted to place the CRA in “any different position whatsoever as a result of the transfer”. The Court found that they did not. More specifically, the Court was of the view that the CRA would have been in the same position if the transferor had transferred the subject property directly to creditors as opposed to indirectly through supposed transferee.

Prepared by: Julia Ji

Julia Ji is an associate practising in the firm’s Toronto office. Julia’s practice includes corporate tax advisory, tax planning, business structuring and tax litigation. Prior to joining Thorsteinssons, Julia was a certified digital project manager specializing in enterprise information architecture… more »