Subsection 183.3(1)
Reorganization
Paragraph (b)
Articles
Joint Committee, "Subject: Proposed Part II.2 Tax – Tax on Repurchases of Equity – ‘Reorganization Transaction", 26 March 2024 Joint Committee Submission
Vertical amalgamations
- It is common for an “Acquisitionco” to acquire all the shares of a public company target (“Targetco”), whose...
Paragraph (c)
Articles
Joint Committee, "Subject: Proposed Part II.2 Tax – Tax on Repurchases of Equity – ‘Reorganization Transaction", 26 March 2024 Joint Committee Submission
Wind-Up of Targetco into Acquisitionco
- A public company target (“Targetco”), whose shares are not delisted until after a delay, is acquired...
Subsection 183.3(2)
Articles
Joint Committee, "Subject: Proposed Part II.2 Tax – Tax on Repurchases of Equity – ‘Reorganization Transaction", 26 March 2024 Joint Committee Submission
Potential duplication under s. 183.3(2)
- Under a literal reading of s. 183.3(2), every covered entity would have an amount under Variable B when...
Variable B
Articles
Joint Committee, "Subject: Proposed Part II.2 Tax – Tax on Repurchases of Equity – ‘Reorganization Transaction", 26 March 2024 Joint Committee Submission
Acquisition of Targetco for cash and Acquisitionco equity
- Where the shareholders of Targetco (which will not be delisted until some time...