Roseland Farms Ltd. v. R., 99 DTC 5704, [1999] 4 CTC 348 (FCTD), aff'd 2001 DTC 5392, 2001 FCA 167 -- summary under Purpose/Intention

By services, 28 November, 2015

Before going on to find that the decision to purchase farm land by the corporation originated with its shareholders, Sharlow J. stated (at p. 5707):

"that the intention of a corporation is that of the natural persons by whom it is managed and controlled ... . In the case of a widely held public corporation, the requisite intention may be that of a corporate officer or a group of officers or directors who made the purchasing decision. The intention of a closely held corporation, however, is normally that of the shareholders."

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