McKesson Canada Corporation v. The Queen, 2014 DTC 1040 [at at 2723], 2013 TCC 404 -- summary under Purpose/Intention

By services, 28 November, 2015

FCA appeal settled.

The taxpayer sold receivables to its Luxembourg parent at over twice the discount which could be supported under s. 247(2)). Boyle J stated (at para. 268):

[T]he predominant purpose and intention of McKesson Canada participating in the… transactions with the other McKesson Group members was not to access capital or to lay off credit risk. Those were results of the transactions but did not motivate them. The purpose was to reduce McKesson Canada's Canadian tax liability... .

Topics and taglines
Topic
General Concepts - Purpose/Intention
Tagline
tax purpose v. commercial result
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
332837
Extra import data
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