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FEDERAL INCOME TAX - Special rules

Friday, August 03, 2018 @ 8:34 AM  

Appeal by Tusk Exploration from a Tax Court judgment affirming assessments and reassessments for the 2002 through 2006 taxation years. The appellant renounced $6.3 million of Canadian Exploration Expenses (CEE). The appellant was unaware that in order to realize the benefit of s. 66(12.66) of the Income Tax Act, the person to whom the expenses were renounced had to be a person at arm's length. An audit determined that 97 per cent of the CEE was to shareholders with whom the appellant was not dealing at...