1. Robert Glegg Investment Inc. v. Canada.
- Author
-
Sommerfeldt, Don R.
- Subjects
ACTIONS & defenses (Law) ,INTERPERIOD tax allocation ,TAXATION of stock transfers ,COVENANTS not to compete ,TAX laws - Abstract
The article discusses the court case Robert Glegg Investment Inc. (RGI) versus Canada on taxation of 54-million-dollar non-competition agreement between RGI, Glegg Industries Inc. (GII) and General Electric Canada Inc. (GE) for the sale of GII shares to GE. The case arose after the Canada Revenue Agency (CRA) rejected the allocation of the entire amount to the agreement in 1999. The Tax Court of Canada ruled that section 68 of the Income Tax Act does not apply to the transaction. The Federal Court of Appeal dismissed the case.
- Published
- 2009