Chapter

A. Were the Transactions Interconnected?

From Walby v. Canada, 2025 FCA 94 | Tax Interpretations by Vente d'un terrain à sa propre société

Concepts

1. Receipt Argument

   "The appellants argue that the two receipts—one for the cash and the other related to the Licenses—should have been treated separately. They submit that there is no statutory mechanism in the Act for

2. Interrelated Transaction

   "The determination of whether the cash paid by Mr. Walby and Mr. De Las Alas was a gift is not confined to only the transactions directly related to the payment of the cash. This Court in Maréchaux v.