Purported distributions out of a purported EPSP to children employees of the taxpayer were to a bank account controlled by the father, so that the participants "never had control of these funds" (para. 40), and so that the "real transactions" were "the payment of amounts by the corporation to the father" (para. 42). See detailed summary under General Concepts –Sham.
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payments not received where children "recipients" had no control over funds
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
333014
Extra import data
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"field_legacy_header": "<a id=\"Dimane\"></a><strong><em>Dimane Enterprises Ltd. v. The Queen</em></strong>, 2015 DTC 1013 [at 64], 2014 TCC 334 <strong>[payments not received where children \"recipients\" had no control over funds]</strong>",
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