The shareholders of a company ("Quebec") purchased a $453,000 note owing by the company for a purchase price of $250,000, payable in 20 semi-annual instalments of $3,750, with the balance of $175,000 payable at the end of the 10 year period. The payment of one of the $3,750 instalments by Quebec, rather than its shareholders, gave rise to a taxable benefit under s. 15(1), notwithstanding that the payee ("Jersey") applied the amount as a reduction of the amount owing by Quebec on the $453,000 note. "What Jersey did, in its books, with the payment, cannot, to my mind, change the character of the transaction as between Quebec and its shareholders."
Topics and taglines
Tagline
shareholder benefit not affected by book entry of shareholder
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
334334
Extra import data
{
"field_legacy_header": "<strong><em>Hall v. The Queen</em></strong>, 86 DTC 6208, [1986] 1 CTC 399 (FCTD) <strong>[shareholder benefit not affected by book entry of shareholder]</strong>",
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"field_sid": "",
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}
"field_legacy_header": "<strong><em>Hall v. The Queen</em></strong>, 86 DTC 6208, [1986] 1 CTC 399 (FCTD) <strong>[shareholder benefit not affected by book entry of shareholder]</strong>",
"field_override_history": false,
"field_sid": "",
"field_topic_category": ""
}