Use of high-PUC, low ACB shares to create CDA (pp. 4-5)
[T]he new rules denied the creation of ACB in shares issued on a stock dividend or...
Introduction of the bifurcation rules (p. 10)
Any other taxable dividend is no longer protected from recharacterization by the internal...
Two main competing interpretations of the “amount” of a stock dividend for purposes of s. 52(3)(a)(ii)(A) (pp. 13-15)
To apply the ACB...
Potential double taxation if safe income crystallized by way of PUC bump (p. 20)
Consequently, for a safe income crystallization, where a PUC bump...