Administrative Policy
26 May 2016 IFA Roundtable Q. 10, 2016-0642101C6 - 93.2 & 95(2)(c)
Canco owns all the shares of FA1, which owns all the shares of FA2 and all the member interests of FA3, which is a “non-resident corporation...
Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(c) | dropdown of shares made to an LLC as a contribution of capital deemed by s. 93.2(3) to be for "share” consideration | 154 |
Tax Topics - Income Tax Act - Section 85.1 - Subsection 85.1(3) | drop-down of FA shares to non-share FA deemed to be for share consideration | 129 |