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

Resource Information

The work St Michael Trust Corp v R Re Fundy Settlement - St Michael Trust Corp v Re Summersby Settlement : 2012 SCC 14 represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

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

Creator

• Avery Jones, J.F
• Nikolakakis, A

Contributor

• Baker, P

Subject

• residence
• tax treaty
• case law
• trust
• central management and control

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

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Language note

English