Gordon Zittlau, "Corporate Reorganizations Involving Taxable Canadian Property – Foreign Merger Considerations", International Tax Planning (Federated Press), Vol. XX, No. 3, 2015, p. 1407

Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition - Paragraph (n)

Taxable Canadian property rules may be engaged by upstream merger (pp. 1407-8)

This article will examine the Canadian tax implications of a...

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Summary Under
Tax Topics - Income Tax Act - Section 87 - Subsection 87(8)

Where there is a merger of two foreign corporations whose shares are taxable Canadian property (because of an underlying Canadian real estate or...

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