Arms Length hmm

I was just reading part of a Canada Revenue Agency Document - that's interesting. Wonder what definition a court would use?

Example 1

A has two adult children, C and D. C has two children, X and Y, and D has one child, Z. A owns all of the issued and outstanding shares of Aco, consequently, A controls Aco. Each of Y and Z owns 50% of the common shares of Opco. Since Y and Z are cousins, they will, for purposes of the Act,

be an unrelated group that controls Opco. As A is related to each of Y and Z (i.e. A is their grandparent), Aco and Opco will be related pursuant to subparagraph 251(2)(c)(iv)

 

 

Corporations and Other Persons

11.Paragraphs 251(2)(b) and (c) set out the statutory rules for determining when a corporation and another person will be considered to be “related persons” (or persons related to each other) for purposes of the Act. Under paragraph 251(2)(b), a corporation will be related to another person

(including another corporation) where:

(a) that person controls the corporation;

(b) that person is a member of a related group that controls

the corporation; or

(c) that person is a person who is related to a person

described in (a) or (b) above.

In addition, paragraph 251(2)(c) provides that two

corporations will be related if:

(i) the two corporations are controlled by the same

person or group of persons;

(ii) each of the corporations is controlled by one

person and the person who controls one

corporation is related to the person who controls

the other corporation;

(iii) one of the corporations is controlled by one

person and that person is related to any member

of a related group that controls the other

corporation;

(iv) one of the corporations is controlled by one

person and that person is related to each member

Prestigious National Award for NL Business Owners

CICPO Wins Prestigious National Lifetime Achievement Award

Celebrating Newfoundland and Labrador professionals and business owners on the National Level.
Read the full story: PRESS HERE

Corporate Garbage - Literally - First up Dominion Supermarket

It is time we did some shaming of our corporations to clean up their garbage.

There is a tree of garbage bags flowing in the wind at Dominion on Stavanger Drive.

The tree looks like it is covered with long flowing white plastic leaves - reminding us that Dominion wants your money but does not want to be responsible for its garbage.

Can you please clean it up.

I will take a picture the next time I am out that way. Let's hope I am just taking a pic of limbs waiting for the spring and real leaves.

If anybody has pics of garbage around our big retailers - send them in so I can post them.

Time to clean the place up both in and outside the Confederation building.

Hard to have pride when we are living in dirt.

Hershey Kiss(off)

Yay for Free Trade - Yay for Free Trade - Yay for Free Trade.

Another 500 jobs lost to Mexico from Ontario - this time it's the Hershey Kiss(off).

Cheaper to do the chocolates in Mexico - I wonder why? Must be the power rates - or maybe its the tax equation - it can't be the labour costs - because free trade was supposed to raise the salaries of Mexicans not lower wages in the United States or Canada - right?

I'm still holding my breath to see what priorities Campbell Soup is going to recommend to the Government of Canada (undermining Canadian values with some warm chicken soup) - or wait the healthcare system might be restructured by Chevron (greasing up private sector delivery) - or wait our education system taking recommendations from Fed-Ex (maybe a speedier delivery)- or wait how about our energy grid getting designed by Wal-Mart (maybe some falling prices or electrical wires).

Let's get a grip here - corporations that have no ability to vote should not be setting our nation's priorities.

They have designed free trade - to move our businesses to Mexico - with our permission - while telling us things are great. What's up with China by the way? Everybody wants to do business there - but they do not have to commit to democracy or human rights - or an open justice system. They can be as insular and undemocratic as they like - but western nations are tripping over each other to get in there.

Free Trade is:

Losing our jobs to Mexico - to enable our corporations to make more money.

Federal Government is:

The mechanism for corporations to change legislation to allow them to move our jobs to Mexico so they can make more money.

Canadian Voter is:

The mechanism for the Liberals and Conservatives to choose which of them can move our jobs to Mexico so Corporations can make more profit.