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S. 84.1(2.3)(a) provides that, for the purposes of s. 84.1(2)(e): (a) if, otherwise than by reason of death, the purchaser corporation disposes of the subject shares within 60 months of their purchase: (i) paragraph [84.1](2)(e)] is deemed never to have applied, [and] (ii) the taxpayer is deemed, for the purposes of [s. 84.1], to have disposed of the subject shares to the person who acquired them from the purchaser corporation …. ...

These are additions to our set of 2,191 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 18 ¼ years of releases of such items by the Directorate. ...

These are additions to our set of 2,200 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 18 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 2,208 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 18 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 2,224 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 18 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 2,249 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 18 ¾ years of releases of such items by the Directorate. ...

Summary of 5 August 2022 External T.I. 2021-0877051E5 F under s. 120.4(1) – related business. ...

These are additions to our set of 2,263 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 18 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,296 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 18 ¾ years of releases of such items by the Directorate. ...

Income Tax Act- Section 256- Subsection 256(2) corporations associated through s. 256(2) continued as associated for s. 129(6) purposes where the 3rd corporation filed s. 256(2) election not to be associated with either 6 November 2003 External T.I. 2003-0039525 F- Canadian Renewable & Conservation Expenses Also released under document number 2003-00395250. ...