10 October 2024 APFF Roundtable, Q.13

Policy Tabs

Summaries

Summary Under

s. 69(5) wind-up of a Newco can be used by trust to realize a capital loss to offset a capital gain realized by it under s. 104(4)(a)

In 2012-0456221R3, CRA ruled that s. 69(5) applied to the winding-up of a Newco so that s. 40(3.6) did not deny the capital loss from the...

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Summary Under

In 2012-0456221R3, CRA ruled that s. 69(5) applied to the winding-up of a Newco so that s. 40(3.6) did not deny the capital loss from the...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Summary Under

post-mortem planning to avoid double taxation is generally not abusive

2012-0456221R3 concerned a spousal testamentary trust which held all the shares of a Canadian investment holding company (Holdco) on the death of...

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