Magren Holdings Ltd. c. Canada — 2024 CAF 202

The Federal Court of Appeal upheld Tax Court assessments imposing Part III tax on capital dividend elections made by three James Grenon-controlled corporations that paid over $110 million in purported capital dividends in 2006, finding the corporations' capital dividend accounts lacked sufficient balances to support those elections. The case clarifies how capital dividend account rules apply in complex trust-reorganisation structures.