Subsection 185(1)
See Also
Magren Holdings Ltd. v. The Queen, 2021 TCC 42
The appellants engaged in transactions which were intended to result in the realization by them of substantial capital gains (resulting in...
Words and Phrases
with all due dispatch| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 185 - Subsection 185(3) | Part III tax assessments of distributions of gains that were denied outside the Part I tax normal reassessment period were not statute-barred | 314 |
| Tax Topics - General Concepts - Ownership | acquisition of income fund units to be held for a few days before their redemption did not represent an acquisition of beneficial ownership | 549 |
| Tax Topics - General Concepts - Sham | transactions did not result in real capital losses | 306 |
| Tax Topics - Income Tax Act - Section 184 - Subsection 184(3) | election was not available where a CDA sham | 365 |
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | no CDA addition where capital gains were not real | 373 |
Subsection 185(3)
See Also
Magren Holdings Ltd. v. The Queen, 2021 TCC 42
The appellants engaged in transactions which were intended to result in the realization by them of substantial capital gains (resulting in...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 185 - Subsection 185(1) | no requirement to issue separate assessment for each election, and no remedy for inordinate time to issue assessments | 396 |
| Tax Topics - General Concepts - Ownership | acquisition of income fund units to be held for a few days before their redemption did not represent an acquisition of beneficial ownership | 549 |
| Tax Topics - General Concepts - Sham | transactions did not result in real capital losses | 306 |
| Tax Topics - Income Tax Act - Section 184 - Subsection 184(3) | election was not available where a CDA sham | 365 |
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | no CDA addition where capital gains were not real | 373 |
Administrative Policy
6 October 2017 APFF Roundtable Q. 10, 2017-0709081C6 F - Election to treat excess as separate dividend
If following, a request for confirmation by CRA of the CDA balance, a capital dividend is paid based on such confirmation, is an assessment of the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 184 - Subsection 184(3) | elected-upon amount is retroactively deemed as income even if it is still unpaid | 279 |