Section 135.1

Subsection 135.1(1)

Allowable Disposition

Administrative Policy

2015 Ruling 2015-0564981R3 - "cross-statute" amalgamation

Background

ACo, which is a CCPC and an agricultural cooperative corporation that was incorporated under Act II, carries on both Business 1 and...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1) amalgamation of 2 corporations in 2 jurisdictions qualified 71

Subsection 135.1(2)

Administrative Policy

25 February 2019 External T.I. 2019-0793911E5 F - Triangular amalgamation and section 135.1

Where s. 87(2)(s) applies to an amalgamation of agricultural cooperative corporations, then shareholders will not be considered to have realized...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(s) - Subparagraph 87(2)(s)(ii) s. 87(2)(s) inapplicable to triangular amalgamation 151

Subsection 135.1(3)

Administrative Policy

25 February 2015 External T.I. 2013-0503941E5 F - Priority of subsections 135(2) or 135.1(3)

In rejecting a submission that the s. 135(2) limitation applies before the s 135.1(3) limitation, and permits the non-deductible excess of...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 135 - Subsection 135(2.1) numerical carryforward example 158