Martin Lee, Manu Kakkar, Thanusan Raveendran, "Section 48.1: TOSI Trap in Going Public", Tax for the Owner-Manager (Canadian Tax Foundation), Vol. 20, No. 1, January 2020, p. 4

Summary Under
Tax Topics - Income Tax Act - Section 120.4 - Subsection 120.4(1) - Split Income - Paragraph (e)

Potential desirability of making s. 48.1 election even where shares are not QSBC shares (p. 4)

Capital gains arising from a disposition of shares...

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Summary Under
Tax Topics - Income Tax Act - Section 48.1 - Subsection 48.1(1)
TOSI rules have resulted in the s. 48.1(1) election being less frequently desirable
  • An election under s. 48.1(1) (where available) deems the electing shareholders to have disposed of their shares of a small business corporation...

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