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Friedlan Law Podcast - Episode 1: Eyeball Networks Inc.

In this the first episode of the Friedlan Law Podcast the subject of discussion is the recent case of Eyeball Networks Inc. v. Her Majesty the Queen, 2019 TCC 150, which considers the application of section 160 to a scenario colloquially referred to by tax practitioners as a related party butterfly. In a wide ranging discussion Adam and Phil consider some of the critical issues relating to the case including the wider of significance of the case to the world of tax planning.
 
 

Hoch v. The Queen, 2019 TCC 99 (CanLII)

For grammar enthusiasts see the case of Hoch v. The Queen, which hinged on whether the word “or” at the end of subparagraph 8(1)(c)(iii) is disjunctive or conjunctive. The Rabbi owned 3/8 of a property…

Notice of Ways and Means Motion to amend the Income Tax Act

The new legislation restricting the availability of the stock option deduction under 110(1)(d) is out. Very roughly speaking securities issued by corporations other than CCPCs or other corporations meeting…

Eyeball Networks Inc. v. The Queen, 2019 TCC 150 (CanLII)

Tax practitioners should check out the recent case of Eyeball Networks Inc. v. The Queen. The case looked at the interaction between section 160 and a related party butterfly transaction. Simplified, the…