Synthetic disposition arrangement

Administrative Policy

20 February 2018 External T.I. 2017-0727811E5 F - Synthetic disposition

Ten months after the formation by him of a small business corporation, Mr. A agrees with an arm’s length employee of the corporation to sell 1/3...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Qualified Small Business Corporation Share disposition could be deferred to end of 24 month period if deferred-closing agreement was not a synthetic disposition agreement 204

Articles

Edward Miller, Matias Milet, "Derivative Forward Agreements and Synthetic Disposition Arrangements", 2013 Conference Report, (Canadian Tax Foundation), pp 10:1-50

Similar U.S. constructive sale proposal (p. 10:26)

Even if one were to decide that 90 percent is generally an appropriate threshold in statutory...

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Ian Caines, Chris Van Loan, "Character Conversion Transactions and Synthetic Disposition Arrangements Updated", Corporate Finance, Volume XIX, No. 1, 2013, p. 219.

One-sided v. two-sided test (p. 2200)

One interesting question that is not fully resolved (but that is highlighted by the inclusion of an...

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