8 June 2016 CTF Technical Seminar: Update on s. 55(2)

Policy Tabs

Summaries

Summary Under

integration principle/expanded scope/no contemplated sale required/no blanket exemptons/policy similar to boot rules

Comments of Yves Moreno and Annie Mailhot-Gamelin (both with the Income Tax Rulings Directorate) on the proposed s. 55(2) rules included:

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Summary Under

safe income appropriately reduced by incentive reductions

CRA considers it to be appropriate from a policy perspective for safe income to be correspondingly lower where incentive deductions have lowered a...

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Summary Under

butterfly rulings may require amending discretionary shares

CRA indicated that it cannot confirm in the context of a butterfly that the pro-rata requirement in s. 55(1) is met where the shares issued are...

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Summary Under

significant reduction in value of nominal value share

After noting that "even if there is no accrued gain on the share that is reduced by a dividend, the significant reduction in fair market value...

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