Words and Phrases - "on"
5 September 2018 Internal T.I. 2017-0698241I7 - Interpretation of subsection 93(4)
FA sub shares acquired “on” disposition of FA parent shares occurring on completion of liquidation and dissolution process
On a liquidation and dissolution (“L&D”) of FA1, it distributed to its parent (ACo) its shares of (wholly-owned) FA2 and FA3 and other...
Words and Phrases
onLocations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Income Tax Act - Section 93 - Subsection 93(2.01) | s. 93(2.01) applied to capital loss resulting from s. 94(3) basis bump | 188 |
Tax Topics - Income Tax Act - Section 93 - Subsection 93(1) | no s. 93 election available where ACB bump under s. 94(3) eliminated gain before application of s. 93(1) | 146 |
10 October 2014 APFF Roundtable Q. 21, 2014-0538091C6 F - 2014 APFF Roundtable, Q. 21 - Impact of the Descarries Case
Descarries failed to recognize breadth of s. 84(2)
What is the CRA position on Descarries? After noting that the case was not appealed because in the result it was favourable and it was only an...
Words and Phrases
onLocations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | Descarries failed to recognize scheme against indirect surplus stripping | 750 |
Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) | will not impose double taxation under s. 84(2) and (3) | 42 |
David v. The Queen, 75 DTC 5136, [1975] CTC 197 (FCTD)
proceeds from the sale of cash-rich company to pension fund for wind-up 5 months later were "otherwise appropriated ... on the winding-up"
Approximately four months after the corporation of which the taxpayers (the "David group") were shareholders sold its principal business assets,...
Words and Phrases
onLocations of other summaries | Wordcount | |
---|---|---|
Tax Topics - General Concepts - Evidence | 30 | |
Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) | 56 |