Carrie Smit, "Foreign Currency Debts and Acquisitions of Control: Beware the Unexpected Gain", International Tax (Wolters Kluwer CCH), February 2017, No. 9, p. 6

Summary Under
Tax Topics - Income Tax Act - Section 111 - Subsection 111(12)

Avoidance of s. 111(12) where simultaneous acquisition of control (AoC) and amalgamation (p. 3)

[2014-05544941E5] found that both the AoC and...

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Summary Under
Tax Topics - Income Tax Act - Section 40 - Subsection 40(11)

If a restructuring of USD debt (with an accrued FX loss) of a Canadian debtor entails an acquisition of control of the debtor before the debt is...

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