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Paragraph 2 of IT-459 states that where such a thing is done only infrequently, or possibly only once, rather than habitually, it is still possible to hold that the person has engaged in a business transaction if it can be shown that he has engaged in an "adventure or concern in the nature of trade". ...

3 May 2022 CALU Roundtable Q. 3, 2022-0928721C6- Recent Changes to Section 84.1-- summary under Paragraph 84.1(2.3)(a) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2.3)- Paragraph 84.1(2.3)(a) disposition is “by reason of death” if a causal link/ if s. 84.1(2.3)(a) applies, s. 84.1 inapplicable if the transaction with the purchaser is not within s. 84.1 The Taxpayer, age 65, retired in the summer of 2021 and thereupon sold and transferred (the “First Disposition”) all the shares (the “Subject Shares”) of his company (“Opco”), which shares were qualified small business corporation shares (having an ACB and PUC of $100,000) to a newly-incorporated wholly-owned corporation (“Purchaser Corporation”) of his adult daughter, Joan (who has been actively engaged in Opco’s business) for their appraised fair market value (FMV) of $2 million. ...

The loan is not made on account of or in full or partial payment of a withdrawal of a limited partner's capital contribution. 2. ...

Third Party also would have a s. 55(3)(a)(ii increase of interest from its transfer of Opco shares to Realtyco for preferred shares (Step 2), as well as when the cross-shareholdings were redeemed (Step 4). ...

Third Party also would have a s. 55(3)(a)(ii increase of interest from its transfer of Opco shares to Realtyco for preferred shares (Step 2), as well as when the cross-shareholdings were redeemed (Step 4). ...