Subsection 93.2(3)

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...

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Locations of other summaries Wordcount
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