Magren Holdings Ltd v. Canada, 2024 FCA 202 -- summary under Sham

By services, 1 December, 2024

In overturning findings of the Tax Court that transactions in income fund units including purchases of such units from an RRSP trust were shams, Monghan JA noted (at para. 171) that the Tax Court had disregarded such transactions, but had failed to consider or even identify the real ones.

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finding of sham must consider what are in fact the real transactions
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d7 import status
Drupal 7 entity type
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Drupal 7 entity ID
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