Marc Ton-That, Vance Sider, "Understanding Section 55 and Butterfly Reorganizations", 2nd Edition, CCH, 1999

Summary Under
Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Safe-Income Determination Time

Harshness of cut-off at beginning of series (being, generally, the beginning of sale negotiations) (pp. 34-35)

Prior to the introduction of the...

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Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(10)

Alleviation of already narrow concept of series (commencing with negotiations) through introduction of SIDT definition (pp. 34-35)

  • Prior to the...

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