Atlantic Packaging Products Ltd. Atlantic Produits D'Emballage Ltée v. The Queen, 2018 TCC 183, aff'd 2020 FCA 75 -- summary under Section 54.2

Summary Under
Tax Topics - Income Tax Act - Section 54.2
s. 54.2 did not apply to the drop-down of under 68% of the assets of a business division to a Newco for Newco shares

The taxpayer was a paper products manufacturer. One of its five divisions was its Tissue Division which focused on the manufacturing and sale of...

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Words and Phrases
substantially all
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) - Paragraph 4(1)(a) prior filing positions contradicted position that tissue division was separate business 437