Rick McLean, Jeff Oldewening, Jonas Lau, "Capital Gains Stripping and Surplus Stripping", 2017 Annual CTF Conference draft paper

Summary Under

Use of high-PUC, low ACB shares to create CDA (pp. 4-5)

[T]he new rules denied the creation of ACB in shares issued on a stock dividend or...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Summary Under

Introduction of the bifurcation rules (p. 10)

Any other taxable dividend is no longer protected from recharacterization by the internal...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Summary Under

Two main competing interpretations of the “amount” of a stock dividend for purposes of s. 52(3)(a)(ii)(A) (pp. 13-15)

To apply the ACB...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Summary Under

Potential double taxation if safe income crystallized by way of PUC bump (p. 20)

Consequently, for a safe income crystallization, where a PUC bump...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

You are here