Kruger Wayagamack Inc. v. The Queen, 2015 DTC 1112 [at at 667], 2015 TCC 90, aff'd 2016 FCA 192 -- summary under Shares

By services, 28 November, 2015

Kruger Inc. was the 51% shareholder of the taxpayer. The taxpayer was associated with Kruger under s. 256(1.2)(c) as the Kruger bloc had more that 50% of the fair market value of all the shares. The 49% bloc might have had a greater value to its current shareholder than that of the 51% bloc to Kruger because of a contingent put right accorded to the minority shareholder under the USA. However, since this put could not be assigned to any third-party purchaser, it did not affect the shares' FMV.

See summary under s. 256(1.2)(c).

Topics and taglines
Topic
General Concepts - Fair Market Value - Shares
Tagline
non-assignable put right ignored
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
332804
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