Magicuts Inc. v. The Queen, 98 DTC 2085, [1999] 1 CTC 2842 (TCC) -- summary under Subsection 15(2.6)

By services, 28 November, 2015

There was insufficient evidence to establish that there was an agreed intention between the taxpayer and its non-resident shareholder to set-off an amount owning by it to the shareholder against amounts owing by the shareholder to it. Accordingly, s. 15(2) and s. 214(3) applied to the amounts owing by it to the shareholder.

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Income Tax Act - s. 15(2.6)
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Node
Drupal 7 entity ID
334402
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