Robson v. Minister of National Revenue, 52 DTC 1088, [1952] CTC 85, [1952] 2 SCR 223 -- summary under Paragraph 82(1)(a)

By services, 28 November, 2015

A corporation, which admittedly was seeking to effect a tax-free distribution of profits to its shareholders, sold shares of another corporation to its shareholders (including the taxpayer) at a substantial undervalue, and the shareholders then sold the shares at a gain. The difference between the fair value of the shares and the amount paid therefor by the shareholders constituted, at the time of the shares' distribution, "dividends or profits directly or indirectly received ... from stocks" for purposes of s. 3(1) of the Income War Tax Act.

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indirect payment
d7 import status
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Node
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338907
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