Bifalgorithm post · Vente d'un terrain à sa propre société · III. Issue and Standard of Review

Issues

Issues (Vente d'un terrain à sa propre société · III. Issue and Standard of Review) — "The appellants, in paragraph 9 of their memorandum, frame the issues as…

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The appeal raises issues concerning the validity and treatment of the donation transactions.
Issues framed by the appellants in paragraph 9
Whether the Tax Court judge erred in finding that the donation to the registered charity was not a valid gift.
Whether the Tax Court judge erred in finding that the split gifting rules vitiated a valid gift.
Issues reframed from the appellants’ arguments
Whether the Tax Court judge erred in treating the transactions as one interconnected series of transactions.
Whether a valid gift exists when the donor expects something of value but does not actually receive anything of value.
Whether the Tax Court judge erred in interpreting value for the purposes of subsection 248(30) of the Act.

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Issues

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Vente d'un terrain à sa propre société

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USR292600b83e2a

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"The appellants, in paragraph 9 of their memorandum, frame the issues as follows:\n\n1) The Tax Court judge erred in finding that the donation to the registered charity was not a valid gift.\n\n2) The Tax Court judge erred in finding that the split gifting rules operated to vitiate a valid gift.\n\nThe issues, based on the arguments made by Mr. Walby and Mr. De Las Alas in their memorandum and at the oral hearing, can be reframed as:\n\n(a) did the Tax Court Judge err in treating the transactions as one interconnected series of transactions;\n\n(b) is there a valid gift if, even though a donor may expect to receive something of value, the donor does not actually receive anything of value; and\n\n(c) did the Tax Court Judge err in his interpretation of value for the purposes of subsection 248(30) of the Act?"

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