His Majesty the King v. Vefghi Holding Corporation et al
His Majesty the King
Law Firm / Organization
Department of Justice Canada
Lawyer(s)

Whitney Dunn

Vefghi Holding Corporation
Law Firm / Organization
Thorsteinssons LLP
Lawyer(s)

Robert Carvalho

S.O.N.S. Environmental Ltd.
Law Firm / Organization
Thorsteinssons LLP
Lawyer(s)

Robert Carvalho

- Parties: The appellant was His Majesty the King. The respondent was Vefghi Holding Corporation and S.O.N.S. Environmental Ltd. 

- Subject Matter: This appeal sought to set aside a Tax Court of Canada order determining a question of law or mixed law and fact under r. 58 of the Tax Court of Canada Rules (General Procedure). The appeal alleged that, where a trust designated a portion of a taxable dividend received on a share of the capital stock of a taxable Canadian corporation under s. 104(19) of the Income Tax Act, such that the amount was deemed received by a beneficiary, the determination of whether the issuer was connected with the beneficiary for purposes of s. 186(1)(a) of the Act was made when the amount was designated by the trust at the end of the particular taxation year of the trust in which the trust received the dividend. This case is ongoing. 

- Date: The hearing was set on Mar. 4, 2025. 

- Venue: This was a federal case before the Federal Court. 

- Amount: No financial award was specified.

Federal Court of Appeal
A-264-23
Taxation
$ 0
04 October 2023