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    <title>1960 (6) TMI 28 - Supreme Court</title>
    <link>https://www.taxtmi.com/caselaws?id=292342</link>
    <description>For purposes of section 68 of the Income Tax Act, a personal corporation required control throughout the taxation year by a natural living individual resident in Canada, or by that individual and family members resident in Canada, or by another person acting on their behalf. Executors administering an estate did not satisfy that requirement because they controlled the shares for multiple beneficiaries rather than for a single qualifying individual or that individual&#039;s family. The broader definitions of &quot;individual&quot; and &quot;person&quot; did not alter the contextual meaning of the provision, and the trust-and-estate rule could not expand the scope of the personal corporation definition. The appellant was therefore not a personal corporation for the relevant taxation years, and the reassessments were upheld.</description>
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    <pubDate>Mon, 13 Jun 1960 00:00:00 +0530</pubDate>
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      <title>1960 (6) TMI 28 - Supreme Court</title>
      <link>https://www.taxtmi.com/caselaws?id=292342</link>
      <description>For purposes of section 68 of the Income Tax Act, a personal corporation required control throughout the taxation year by a natural living individual resident in Canada, or by that individual and family members resident in Canada, or by another person acting on their behalf. Executors administering an estate did not satisfy that requirement because they controlled the shares for multiple beneficiaries rather than for a single qualifying individual or that individual&#039;s family. The broader definitions of &quot;individual&quot; and &quot;person&quot; did not alter the contextual meaning of the provision, and the trust-and-estate rule could not expand the scope of the personal corporation definition. The appellant was therefore not a personal corporation for the relevant taxation years, and the reassessments were upheld.</description>
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      <pubDate>Mon, 13 Jun 1960 00:00:00 +0530</pubDate>
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