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15 September 2020 IFA Roundtable, Q.6
15 September 2020 IFA Roundtable, Q.6
Policy Tabs
Summaries
Summaries
Summary Under
Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(9) - Paragraph 212.3(9)(b) - Subparagraph 212.3(9)(b)(ii)
reinstatement arguably occurs on distributing shares of sub capitalized with daylight loan
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Summary Under
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4)
circular transactions to effect a s. 212.3(9)(b)(ii) PUC reinstatement abused that provision
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