Sheldon Inwentash and Lynn Factor Charitable Foundation v. Canada, 2012 FCA 136 -- summary under Paragraph 251(1)(c)

By services, 5 April, 2024

In the course of finding that a trust, which was a charitable foundation, did not qualify as a public foundation as it had a single trustee (a registered trust company), Dawson JA stated (at para. 32):

Moreover, a single trustee is not at arm’s length from itself.

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Income Tax Act - s. 251(1)(c)
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a person does not deal at arm’s length with itself
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