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Tax Interpretations
Canadian tax interpretations and transactional implications
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7 December 1990 Income Tax Severed Letter - Section 85 transfer by non-tesident; Trusts—dividends paid to corporate beneficiary; Capital gains deduction—sale to spouse; GAAR—sale of shares; Income or capital gain: Rollover of assets followed by immediate sale of assets; Winding-up—cost amount of inventory; Rollover under section 85—benefit conferred on a related person; Deemed dividend on winding-up; Services between related Canadian corporations—paragraph 69(1)(b); Stock dividends; Indirect acquisition of control
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(Your name) has forwarded "7 December 1990 Income Tax Severed Letter - Section 85 transfer by non-tesident; Trusts—dividends paid to corporate beneficiary; Capital gains deduction—sale to spouse; GAAR—sale of shares; Income or capital gain: Rollover of assets followed by immediate sale of assets; Winding-up—cost amount of inventory; Rollover under section 85—benefit conferred on a related person; Deemed dividend on winding-up; Services between related Canadian corporations—paragraph 69(1)(b); Stock dividends; Indirect acquisition of control" - Tax Interpretations
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