Can the Minister assess a taxpayer under section 160 in respect of an amount already included in the taxpayer’s income under subsection 15(1)? From Justice Bocock, in Parihar v R, 2015 TCC 52 at ¶45: shareholder who has been…
Payments on behalf of a corporation avoid 160
In Muir v R, 2020 TCC 8 (informal procedure), a corporation, after selling its dental practice, paid an amount to the controlling shareholder at a time when the corporation owed tax. The Court (Boyle J) found that (1) that the…