Principal Issues: Whether our position with respect to Employee Buycos, as stated at the CRA Panel held at the 2012 CTF Annual Conference, has...

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Principal Issues: Does income that is attributed or allocated to another taxpayer, under certain specified provisions of the Act, need to be...

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Principal Issues: Can a non-resident individual holding shares of a Canadian corporation that have been deemed to be disposed of upon the...

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Principal Issues: 1. Does the CRA consider that a deferred gain resulting from the application of subsection 261(10) can be realized in the year...

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PRINCIPAL ISSUES: In a particular situation, there is a class of preferred shares that are non-voting, non-participating, with a redemption value...

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Principal Issues: 1.Whether a trust that ceases to be resident in Canada can make an election under subsection 220(4.5)? 2. Whether the Minister...

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Principal Issues: Whether subsection 84(2) and/or 245(2) would apply in a situation involving a partial leveraged Buy-out.

Position: General...

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Principal Issues: Is the asset recorded as a capital property as a result of a lease of an asset considered used principally in an active business...

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Principal Issues: Whether the condition under subparagraph 110.6(1.3)(a)(i) is met when a child acquires a land from his estate’s father during...

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Principal Issues: Does the CRA position in paragraph 22 of Interpretation Bulletin IT-268R4 apply to a person who is a shareholder but not an...

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