Words and Phrases - "reorganization"

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82
b
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d
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71
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51
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25
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Foix v. The Queen, 2021 TCC 52, aff'd 2023 FCA 38

Summary Under
Tax Topics - Income Tax Act - Section 84 - Subsection 84(2)
s. 84(2) applied to a hybrid sale transaction resulting in shareholders receiving corporation's asset sales proceeds as capital dividends and sales proceeds of bumped shares

The shareholders of a private Canadian company (“W4N”) exploiting a valuable item of software had agreed in principle to sell W4N to a U.S....

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Words and Phrases
reorganization

Christian Desjardins, Nik Diksic, "Cross-Border Butterflies in the Context of Public Spin-Off Transactions", 2015 CTF Annual Conference paper

Summary Under
Tax Topics - Income Tax Act - Section 55 - Subsection 55(3.1) - Paragraph 55(3.1)(b)

History of s. 55(3.1)(b) (pp. 29:3)

[The main purpose of the original version of subsection 55(3.1) was to prevent…using the butterfly exemption...

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Words and Phrases
reorganization
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Distribution 1300

1996 Corporate Management Tax Conference Roundtable, Q. 16 (Canadian Tax Foundation), at 24:19

Summary Under
Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Distribution
narrow scope of "reorganization"

When does a reorganization end (that is, when are subsequent transactions considered part of the "reorganization" and when are they outside the...

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Words and Phrases
reorganization

13 January 1993 External T.I. 5-923395

Summary Under
Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1) - Paragraph 110(1)(d)

RC does not as a general rule express an opinion on the reasonableness of a method proposed to be used in arriving at the fair market value of a...

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Words and Phrases
reorganization
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1.5) 87

Kennedy v. MNR, 72 DTC 6357, [1972] CTC 429 (FCTD), aff'd 73 DTC 5359 (FCA)

Summary Under
Tax Topics - Income Tax Act - Section 84 - Subsection 84(2)
sale-leaseback of principal asset did not change the manner and form in which business carried on: no reorganization

A corporation of which the taxpayer was the sole shareholder purchased a property for use as the new site for its car dealership business, paid...

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Words and Phrases
reorganization