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In the Canadian income tax case of 9044-2807 Québec Inc. v The Queen, 2004 FCA 23, the Federal Court of Appeal held that corporations were associated under subsection 256(5.1) of the Income Tax Act by virtue of de facto control based on the controlling influence of one corporation on the other..

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"This article provides information of a general nature only. It is only current at the posting date. It is not updated and it may no longer be current. It does not provide legal advice nor can it or should it be relied upon. All tax situations are specific to their facts and will differ from the situations in the articles. If you have specific legal questions you should consult a lawyer."

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