Geoffrey S. Turner, "June 2014 Election Deadlines for Retroactive Application of New Foreign Affiliate Reorganization Rules", CCH International Tax, No. 74, February 2014, p. 1.

Summary Under
Tax Topics - Income Tax Act - Section 88 - Subsection 88(3.3)
Suppression election addresses excess of inside over outside basis (p. 6)

Importantly, new subsection 88(3.3) provides for a "suppression...

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Summary Under
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(d.1)
2011 broadening (p. 4)

The new foreign affiliate merger rollover in paragraph 95(2)(d.1) has been amended, among other things, to eliminate the...

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Summary Under
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(e)
2011 introduction of DLAD (p. 4)

New paragraph 95(2)(e) replaces the "90% surplus entitlement percentage" and "foreign non-recognition" conditions...

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Summary Under
Tax Topics - Income Tax Regulations - Regulation 5901 - Subsection 5901(2) - Paragraph 5901(2)(b)
Retroactive election (p. 3)

… Bill C-48 permits taxpayers to electively apply Regulation 5901(2)(b) (together as a package with subsections...

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