DAC Investment Holdings Inc. v. The King, 2024 TCC 63 -- summary under Section 123.3

By services, 9 May, 2024

With a view to its imminent disposition of the shares of a subsidiary, the taxpayer continued to the British Virgin Islands, with the result that it ceased to be a Canadian-controlled private corporation (CCPC) and became a private corporation that was not a CCPC (its central management and control remained in Canada). CRA assessed on the basis inter alia that the resulting non-application of s. 123.3 (imposing refundable tax) was an abuse of that provision.

In finding no abuse of s. 123.3, D’Arcy stated (at para. 227):

Parliament has chosen, for policy reasons, to have different sets of rules for different corporations. …

Before so concluding, he stated (at paras. 137-138):

[The] history of the definition of RDTOH shows that Parliament intended for the refundable tax regime for Part I tax, which now includes section 123.3, to only apply to CCPCs. …

In my view, the text, context and purpose of section 123.3 does not support a finding that its object, spirt and purpose was to prevent Canadian resident individuals from deferring tax on investment income held in any private corporations. [emphasis in original]

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object of s. 123.3 was to impose refundable tax only on CCPCs
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d7 import status
Drupal 7 entity type
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Drupal 7 entity ID
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