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4 January 2022 External T.I. 2015-0607531E5 F- Action admissible de petite entreprise-- summary under Subparagraph 110.6(14)(f)(i) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(14)- Paragraph 110.6(14)(f)- Subparagraph 110.6(14)(f)(i) s. 110.6(14)(f)(i) can apply to an amalgamation S. 110.6(14)(f)(i) provides that, for purposes of the requirement in s. 110.6(1)(b) that mooted qualified small business corporation shares ("QSBCSs") must not have not been owned during the 24 months preceding their disposition (the “determination time”) by anyone other than the disposing individual or a related person or partnership, such shares will be considered to have been so owned prior to their issuance by a “bad” owner unless they were issued as consideration for other shares (the “original shares”). ... X) exchanges his majority shareholding of Opco for shares of a new personal holding company Holdco) and then, around a year later, receives replacement shares of Amalco on an amalgamation of Holdco with Opco followed by a sale by him (and the minority shareholder) of their Amalco shares to a third party, CRA accepted that s. 110.6(14)(f)(i) applied on the amalgamation, i.e., that the Amalco shares could be regarded under the scheme of the Act as being “issued” in consideration for the shares of the relevant predecessor (Holdco). ...

In 2010, Parent sold his shares of Parentco to his child for FMV cash consideration (thereby realizing gain at which time the marketable securities were the only assets of Parentco.) The child shortly thereafter transferred the shares of Parentco to a newly incorporated corporation ("Childco") in consideration for a demand promissory note, and wound-up Parentco. ...

A and B), who each hold a 50% block of the common shares of a small business corporation (Dividend Payor) having a fair market value of $1.5M and nominal adjusted cost base and paid-up capital, and safe income on hand of perhaps $1M, transfer their respective shareholdings to wholly-owned Newcos (Holdco A and Holdco B), utilizing the s. 85(1) rollover, in consideration for common shares of Holdco A and Holdco B with the same attributes (FMV- $1.5M; nominal ACB and PUC). Each of the two Holdcos then transfers its common shares of Dividend Payor under s. 85(1) to Dividend Payor in consideration for the issuance by Dividend Payor of preferred shares, also with such attributes (FMV- $1.5M; nominal ACB and PUC). ...

X to Opco in the course of incorporating his business, nor... to the consideration paid by Mrs. ... [T]he consideration paid by Mr. or Mrs. X for the acquisition of shares in the capital of Holdco, which is not an SBC, would technically constitute a transfer of property by an individual (Mr. or Mrs. ...

…[T]he consideration paid by Opco to Holdco for the acquisition of preferred shares in the capital of Holdco would never accrue personally to Mr. ... X under s. 85(1) to Holdco in consideration for Holdco preferred shares, and Opco redeems its preferred shares in the same amounts as the 1 st situation. ...

22 January 2016 External T.I. 2015-0617601E5 F- Pipeline followed by butterfly-- summary under Subsection 84(2) Summary Under Tax Topics- Income Tax Act- Section 84- Subsection 84(2) pipeline transaction can be coupled with a butterfly split-up An estate acquires the shares of Corporation 1 on a stepped-up basis under s. 70(5) and, in August 20X0, transfers the shares to Corporation 2 (whose common shares are held by it) in consideration for preferred shares with full paid-up capital and adjusted cost base (and without s. 84.1 applying). ... One of the important facts …is that following the winding-up…there would not be a bulk redemption of the preferred shares in the capital of Corporation 2…and there would not be a bulk redemption of the shares in the capital of Corporations 3 and 4…received in consideration for the preferred shares in the capital of Corporation 2. ...

They then implemented a divisive reorganization of Opco under which B disposed of her Opco common shares to Newco (newly-incorporated by her) in consideration for Newco common shares, Opco disposed of a portion of its business property to Newco in consideration for Newco preferred shares and the two shareholdings were cross-redeemed for notes that were then set off. ...

21 October 2014 External T.I. 2014-0543041E5- Class 43.2- Photovoltaic System-- summary under Class 43.2 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 43.2 solar panels General discussion of the considerations applicable to claiming CCA on solar photovoltaic systems. ...

(August 1990 Access Letter, ¶1387)-- summary under Subsection 146.3(6) Summary Under Tax Topics- Income Tax Act- Section 146.3- Subsection 146.3(6) Where the surviving spouse is not named as beneficiary in either the RRIF application or the will but is the sole beneficiary of the will, the taxpayer should submit complete details in writing to his local district taxation office for consideration. ...

No. 2, p. 11, ¶1062)-- summary under Subsection 80(1) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(1) Where receivables are transferred to the debtor corporation in consideration for treasury shares, s. 80 applies if the fair market value of the shares is less than the principal amount of the debt. ...