1993 A.P.F.F. Round Table, Q. 25

S.116 would not normally apply in a situation where a capital gain arises under s. 40(3) on a distribution of paid-up capital to a U.S. resident.

A capital gain arising as a result of a distribution of paid-up capital on common shares held by a non-resident generally would be exempt under...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.