Rick McLean, "Subsection 55(2): What Is the New Reality?", 2015 CTF Annual Conference paper

Summary Under
Tax Topics - Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(b)

Example of planning engaging the introduction of the expanded s. 55(2.1)(b) test respecting increases in cost amount (pp. 22:9-12)

Holdco owns...

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Summary Under
Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Safe-Income Determination Time

Application of safe-income determination time to annual cash dividends (p. 22:43)

The legislative definition of "safe-income determination...

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Summary Under
Tax Topics - Income Tax Act - Section 55 - Subsection 55(2.3)

Potential application of s. 55(2) to stock dividend of high-low shares (pp. 22:63-64)

Holdco owns all of the shares (being common shares) of Opco...

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