Entity-by-entity application of test (p.9)
- The test of all or substantially all of the businesses, undertakings and activities of each eligible...
Exceeding of $5M threshold even where small FA interest or stacking of FAs (p. 9)
- The test of the total fair market value of all property of a...
Likely requirement to hold a share (pp. 10-11)
- Presumably the position in 2019-0798831C6, that a person must own at least one share of a...
Application where share sale but not asset sale (pp. 11-12)
- Where, for example, a Canadian-resident taxpayer has a subsidiary that causes it to...
Reduction for FAT claims in future years (p. 20)
- The inclusion under para. (g) of the interest and financing revenues definition of the relevant...
Application of RIFE first (p. 30)
- A taxpayer’s excess capacity (generally arising where the maximum amount a taxpayer is permitted to deduct in...
Requirement for accuracy (p. 34)
- Any over-designation, including an immaterial one, will invalidate a transfer of excess capacity under s....
Zero tolerance for errors (p. 39)
- Under s. 18.21(2), if an election is made that allocates an amount greater than the specified limits, the...