Charles P. Marquette, "Hybrid Sale of Shares and Assets of a Business", Canadian Tax Journal, (2014) 62:3, 857 – 79.

Summary Under
Tax Topics - Income Tax Act - Section 191 - Subsection 191(4)
CRA interpretation of specified amount (pp. 877-8)

[I]n a hybrid transaction in in which a redemption of the shares will trigger a deemed...

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Summary Under
Tax Topics - Income Tax Act - Section 84 - Subsection 84(2)
Description of hybrid transaction using external step-up in basis method (pp. 878-9)

[T[he hybrid form of transaction for a corporate business...

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