A sale by the taxpayers (a husband and wife) of their shares of a controlled corporation to another corporation ("9061") all of whose shares were held by a trust of which they and the family accountant were the trustees did not represent a sale of those shares to a related person given that decisions of the trust were required to be made unanimously, so that the taxpayers did not have de jure control of the purchaser corporation.
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d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
337572
Extra import data
{
"field_legacy_header": "<strong><em>Côté-Létourneau v. The Queen</em></strong> , 2010 DTC 1116 [at 3092], 2007 TCC 91",
"field_override_history": false,
"field_sid": "",
"field_topic_category": "seealso"
}
"field_legacy_header": "<strong><em>Côté-Létourneau v. The Queen</em></strong> , 2010 DTC 1116 [at 3092], 2007 TCC 91",
"field_override_history": false,
"field_sid": "",
"field_topic_category": "seealso"
}