Brian R. Carr, Julie A. Colden, "The Bump Denial Rules Revisited", Canadian Tax Journal (2014) 62:1, 273-99.

Summary Under
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(c) - Subparagraph 88(1)(c)(vi) - Clause 88(1)(c)(vi)(B) - Subclause 88(1)(c)(vi)(B)(II)
Overview of aggregation rule (p. 283)

In addition, the bump will be denied if distributed property or substituted property is acquired as part of...

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Summary Under
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(c) - Subparagraph 88(1)(c)(vi) - Clause 88(1)(c)(vi)(B) - Subclause 88(1)(c)(vi)(B)(III)
Specified shareholder must not also own 10% of shares of an acquiror (either alone or with non-arm's length persons): s....

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Summary Under
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(c) - Subparagraph 88(1)(c)(vi)
Purpose of bump denial rules (p. 276)

…Generally, the bump denial rules were introduced into the Act to prevent so-called back-door...

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Summary Under
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(c.2) - Subparagraph 88(1)(c.2)(i)
Related status before incorporator's share issuance (p. 297)

The joint [CBA/CICA] committee noted in its submission that there are deficiencies in...

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Summary Under
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(c.2) - Subparagraph 88(1)(c.2)(ii)
Look-through specified shareholder definition v. s. 88(1)(c.2)(ii) entity approach (p. 288)

As a result of the interaction of subparagraph...

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Summary Under
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(c.3) - Subparagraph 88(1)(c.3)(i)
Upstream equity or debt as substituted property (p. 280)

Any upstream equity interests (such as shares of the parent or other upper-tier...

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Summary Under
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(c.4) - Subparagraph 88(1)(c.4)(ii)
Dissent payment rights under a plan of arrangemnt as indebtedness (p. 292)

If the plan of arrangement ultimately receives shareholder approval,...

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Summary Under
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(c.9)
No relief under s. 88(1)(c.9) for conventional option exchange (pp. 294-5)

Technically, however, the proposed amendment provides no relief if an...

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