The Resource St Michael Trust Corp v R Re Fundy Settlement - St Michael Trust Corp v Re Summersby Settlement : 2012 SCC 14

St Michael Trust Corp v R Re Fundy Settlement - St Michael Trust Corp v Re Summersby Settlement : 2012 SCC 14

Label
St Michael Trust Corp v R Re Fundy Settlement - St Michael Trust Corp v Re Summersby Settlement : 2012 SCC 14
Title
St Michael Trust Corp v R Re Fundy Settlement - St Michael Trust Corp v Re Summersby Settlement : 2012 SCC 14
Creator
Contributor
Subject
Language
eng
Summary
Judgment by the Supreme Court of Canada, dated 12 April 2012. The central issue concerned the residence of a trust for Canadian tax purposes. St Michael was a Barbados trust corporation which was the trustee of two settlements of shares in subsidiaries made by a Canadian company owned by two Canadian businessmen. Each settlement had as its beneficiaries one of the Canadian businessmen and his relatives. The trial judge found that the trustee company was not exercising the powers and discretions of a trustee but acting on the instructions of the beneficiaries, even after a reorganisation of the shareholding. The trust therefore was resident in Canada and taxable in Canada
Citation source
In: International tax law reports. - London. - Vol. 14 (2012),
http://bibfra.me/vocab/relation/comm
  • wgxhYUYtE4w
  • 2ul8NlLeYHs
http://library.link/vocab/creatorName
  • Avery Jones, J.F
  • Nikolakakis, A
Language note
English
http://library.link/vocab/relatedWorkOrContributorName
Baker, P
http://library.link/vocab/subjectName
  • case law
  • tax treaty
  • trust
  • residence
  • central management and control
Label
St Michael Trust Corp v R Re Fundy Settlement - St Michael Trust Corp v Re Summersby Settlement : 2012 SCC 14
Instantiates
Publication
Label
St Michael Trust Corp v R Re Fundy Settlement - St Michael Trust Corp v Re Summersby Settlement : 2012 SCC 14
Publication

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