Before finding that the taxpayers had not entered into an arrangement with the requisite intention to be partners, the Court stated (at para. 22) that "motivation is that which stimulates a person to act, and intention is a person's objective or purpose in acting. This Court has repeatedly held that a tax motivation does not derogate from the validity of transactions for tax purposes ...".
Topics and taglines
Tagline
motivation v. purpose
Words and phrases
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
332829
Extra import data
{
"field_legacy_header": "<strong><em>Backman v. The Queen</em></strong>, 2001 DTC 5149, 2001 SCC 10 <strong>[motivation v. purpose]</strong>",
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"field_sid": "",
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}
"field_legacy_header": "<strong><em>Backman v. The Queen</em></strong>, 2001 DTC 5149, 2001 SCC 10 <strong>[motivation v. purpose]</strong>",
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}
Workflow properties
Workflow state