After finding that break fees totalling $7.7 million received by the taxpayer in an unsuccessful acquisition attempt were fully taxable to it under s. 9 given that "its ordinary business activities included trying to make corporate acquisitions such as its bid for Acanthus resulting in the break fee" (para. 45), Boyle J. briefly considered the Minister's alternative argument that the break fee was reimbursement under s. 12(1)(x) for the taxpayer's expenses in preparing the takeover bid. He stated obiter dicta that it was unlikely that the entire $7.7 million could be construed as reimbursement.
Topics and taglines
Tagline
break fee not all reimbursement
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
333767
Extra import data
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"field_legacy_header": "<strong><em>Morguard Corporation v. The Queen</em></strong>, 2012 DTC 1099 [at 2959], 2012 TCC 55, aff'd 2013 DTC 5009 [at 5554], 2012 FCA 306 <strong>[break fee not all reimbursement]</strong>",
"field_override_history": false,
"field_sid": "",
"field_topic_category": "seealso"
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