Income Tax Technical News No. 44 13 April 2011 [archived]

If a typical loss-consolidation transaction results in an incidental shifting of income or losses between provinces, simply because the...

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In finding that the appreciated amount of an exchangeable debenture when paid on maturity could not be recognized under s. 20(1)(e), CRA...

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Before the decision in Imperial Oil Ltd. and Inco Ltd....CRA's position with respect to exchangeable debentures issued with or without an ...

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CRA stated:

[W]hen a holder of an exchangeable debenture exercises the right to exchange the debenture for the target shares, the holder would...

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Is it CRA's position that "where property is transferred to a corporation by a shareholder for no consideration, the corporation will not have any...

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After commenting on a transaction in which a ULC held by a US C corporation (USco) increases its paid-up capital (giving rise to a deemed...

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