Subsection 51(2) - Idem [Convertible property]

Administrative Policy

11 April 2005 External T.I. 2005-0112321E5 F - Price adjustment clause

An estate freeze entailed the exchange by Mr. A of his common shares of Opco by way of purchase for cancellation for Class A preferred shares with...

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Tax Topics - General Concepts - Effective Date CRA may also accept a price adjustment clause for improving the attributes of the shares received on an exchange so as to equal the exchange price 332
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) where FMV of pre shares received on estate-freeze s. 51 exchange was less than that of the exchanged common shares, CRA would apply s. 51(2), not s. 15(1) 142

1996 Corporate Management Tax Conference Round Table, Q. 13 (C.T.O. "Benefit of Conversion")

Although s. 51(2) does not contain an exclusion for wholly-owned corporations, ordinarily RC would not consider that it is reasonable to regard...

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Tax Topics - Income Tax Act - Section 86 - Subsection 86(2) 64