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 |
S4-F3-C1 - Price Adjustment Clauses
CRA will consider a price adjustment clause to represent pricing at fair market value if:
- the agreement reflects a bona fide intention of the...
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 |