The recognition of a loss realized by the taxpayer on a non-interest bearing loan made by him to a company owned by a family trust was denied given that under the terms of the trust the trustees could pay the income of the trust to any beneficiary to the exclusion of the others (including the taxpayer) and the taxpayer could not secure a distribution to him without the votes of the other two trustees.
Topics and taglines
Tagline
Byram distinguished: Opco income might never accrue to beneficiary
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
337972
Extra import data
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}
"field_legacy_header": "<strong><em>Toews v. The Queen</em></strong>, 2005 DTC 1359, 2005 TCC 597",
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