Langille v. The Queen, 2009 DTC 1103 [at at 564], 2009 TCC 139 -- summary under Specified Investment Business

By services, 28 November, 2015

The taxpayer who was the sole director and officer of a corporation ("Alland") owned by him and a family trust, lent money in order for Alland to participate over the course of 15 months in what the taxpayer thought were purchases of inventory by another corporation ("Trev Cor"), with Alland to receive a share of the profits from resale of the inventory. In fact, Trev-Cor was engaged in a pyramid scheme so that few or none of the transactions actually occurred. Given the active involvement of the taxpayer in determining whether Alland should participate in the transactions and the fact that the transactions were found to be joint venture transactions with Trev-Cor, Alland was not engaged in a specified investment business, so that the losses sustained by the taxpayer on his loans to Alland were business investment losses.

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Tagline
unwitting pyramid scheme
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
333896
Extra import data
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