Peter Lee, Annika Wang, "The Tracking Interest Rules", International Tax (Wolters Kluwer CCH), No. 193, December 2018, p.5

Summary Under
Tax Topics - Income Tax Act - Section 95 - Subsection 95(8)

Different types of segregated account companies (“SACs”) (p. 5)

The late 1990s saw the emergence of a new form of corporate vehicle,...

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Summary Under
Tax Topics - Income Tax Act - Section 95 - Subsection 95(11) - Paragraph 95(11)(e)

S. 95(11)(e) rule (p. 9)

[I]f the taxpayer holds: (1) property that is a tracking interest in an affiliate; and (2) shares of a class of the...

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