Wong v. R., 99 DTC 458, [1999] 2 CTC 2173 (TCC) -- summary under Subsection 15(1.1)

By services, 28 November, 2015

It was accepted that the effect of an arrangement under which family members subscribed for non-voting Class B common shares of a corporation carrying on the taxpayer's medical practice, with the corporation then paying significant stock dividends to them, was to significantly reduce the taxpayer's interest in the corporation. However, Rowe D.J. accepted evidence that the sole purpose of the stock dividends was to split income with the family members and that there was no intent to reduce the value of the taxpayer's shareholdings, it being accepted that the possibility of ever selling shares in his incorporated medical practice was very remote.

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