After OSFC, the Supreme Court of Canada next considered the GAAR in Canada Trustco Mortgage Co v Canada, (40) which dealt with a company's scheme to obtain capital cost allowance against its leasing income.
Reflecting on OSFC, Duff remarks that Rothstein JA's judgment stands to limit the GAAR's effectiveness insofar as it requires the CRA to establish that the avoidance transaction abused a "clear and unambiguous" policy.
It is worth recalling that in OSFC, Rothstein JA held that the provisions of the Act, read as a whole, bear a general policy against loss transfers between corporate taxpayers.
The Ohio School Facilities Commission (OSFC) was created as a partial response to the Ohio Supreme Court's 2001 DeRolph v.
As these and other developments suggest, the story of Warren's three decades of school consolidation, which opened with an emphasis on desegregation and gradually focused on fiscal considerations (new schools constructed with OSFC funding), has been informed by missteps and questionable motives.
Orissa State Financial Corporation (OSFC) was established started functioning in 1957.
OSFC had assisted basic and capital good industries like motels, electrical, transport equipment, chemicals and fertilizers machinery, etc.
This concept is reflected in the OSFC
standards that he helped to develop.
In Imperial Oil, the same conclusion was reached by the lower courts, though they had used (understandably) a different analytical approach (i.e., the approach in OSFC
Will CCRA explain how the court's broad comments in the OSFC
decision affect CCRA's application and interpretation of the definition of "series of transactions or events" in subsection 248(10)?
Selected consultants will also be required to participate in 21st Century Education Workshops and the OSFC
21C Studio, an online learning community.
The existing Segment 6 Project Agreement between the District and OSFC
will be amended to include this project.