Capital gains reserves cannot be claimed under reverse earnouts
2 April 2014 - 8:30am
CRA considers that no capital gains reserve can be claimed where shares are sold on a reverse earn-out, given that the proceeds of disposition are not certain at the moment of sale.
Neal Armstrong. Summary of 24 February 2014 T.I. 2013-0505391E5 F under s. 12(1)(g).