Section 110.6

Table of Contents

Subsection 110.6(1) - Definitions

Annual Gains Limit

Administrative Policy

6 December 2017 External T.I. 2016-0667361E5 F - Taxable Capital Gains Designation

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(21.2) eligibility of a gain for the capital gains deduction is lost when it is distributed by a lower-tier to upper-tier trust 265

86 C.R. - Q.49

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Cumulative Net Investment Loss

Administrative Policy

1990 Answers of Calgary District Office (May 1990 Access Letter, ¶1200, Q. 11)

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Eligible Real Property Gain

Administrative Policy

21 June 1993 T.I. (Tax Window, No. 32, p. 8, ¶2600)

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Interest in a Family Farm or Fishing Partnership

Administrative Policy

13 July 2016 External T.I. 2013-0478961E5 F - Interest in a family farm or fishing partnership

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Paragraph (a)

Subparagraph (a)(i)

Administrative Policy

6 October 2017 APFF Roundtable Q. 16, 2017-0709161C6 F - Résidence principale sur une terre agricole

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property non-severable farm is a single indivisible property 111

18 June 2015 External T.I. 2015-0572791E5 F - Société de personnes agricole familiale - BAA

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Interest in a Family Farm Partnership

Administrative Policy

21 January 1991 T.I. (Tax Window, Prelim. No. 3, p. 23, ¶1098)

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Investment Expense

Administrative Policy

3 July 1991 T.I. (Tax Window, No. 5, p. 21, ¶1336)

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13 March 1991 T.I. (Tax Window, No. 1, p. 17, ¶1142)

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28 May 1990 T.I. (October 1990 Access Letter, ¶1446)

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89 C.P.T.J. - Q8

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Investment Income

Administrative Policy

13 January 1993 T.I. 923208 (November 1993 Access Letter, p. 505; Tax Window, No. 28, p. 15, ¶2382)

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Non-Qualifying Real Property

Administrative Policy

22 July 1994 External T.I. 5-940136 -

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12 January 1993 T.I. 923151 (November 1993 Access Letter, p. 503, ¶C109-154)

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Words and Phrases
principally

8 January 1993 T.I. 922776 (November 1993 Access Letter, p. 503, ¶C109-155; Tax Window, No. 28, p. 5, ¶2367)

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Articles

Hirsch, "Capital Gains Exemption in Real Property", 1992 Conference Report, c.11.

Qualified Farm or Fishing Property

See Also

Otteson v. The Queen, 2014 DTC 1173 [at 3637], 2014 TCC 250

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 96 no presumption that spouses are not business partners 174

Administrative Policy

11 June 2015 External T.I. 2014-0522641E5 F - Usufruct

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Tax Topics - Income Tax Act - 101-110 - Section 108 - Subsection 108(7) creation of usufruct between father and son, resulting in deemed trust, did not entail property transfer to the deemed trust 284
Tax Topics - Income Tax Act - Section 73 - Subsection 73(3) creation of usufruct between father and son entails transfer of trust interest, not farm property 156

10 March 2015 External T.I. 2014-0552551E5 F - Vente du droit d'exploiter une sablière

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate application of capital gains criteria on woodlots to sale of rights to extract sand 49
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(g) sale of rights to extract sand generally not caught unless a profit à prendre 122

28 January 2014 External T.I. 2014-0517601E5 - Qualified farm Property

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16 March 1998 External T.I. 5-963813 -

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27 December 1995 T.I. 953277 [grazing leases]

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1994 Institute of Chartered Accountants of Alberta Roundtable Q. 20, 7-940973 -

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5 April 1994 External T.I. 5-933648 -

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12 May 1994 T.I. 940692

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23 June 1993 T.I. (Tax Window, No. 32, p. 14, ¶2609)

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11 February 1993 T.I. (Tax Window, No. 29, p. 18, ¶2423)

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7 December 1992 T.I. (Tax Window, No. 27, p. 18, ¶2325)

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92 C.R. - Q.52

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30 July 1992 T.I. 921204 (January - February 1993 Access Letter, p. 26, ¶C109-125)

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9 October 1990 T.I. (Tax Window, Prelim. No. 1, p. 17, ¶1035)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) 36

7 October 1991 T.I. (Tax Window, No. 10, p. 13, ¶1508)

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19 June 1990 T.I. (November 1990 Access Letter, ¶1526)

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28 May 1990 T.I. (October 1990 Access Letter, ¶1472)

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8 September 89 T.I. (February 1990 Access Letter, ¶1116)

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Qualified Small Business Corporation Share

Cases

Hudon v. Canada, 2001 DTC 5630, 2001 FCA 320

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See Also

Durocher v. The Queen, 2016 DTC 1013 [at 2584], 2015 TCC 297, aff'd 2016 CFA 299

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Canadian-Controlled Private Corporation potential illegality of an option to acquire control of a private corporation did not nullify the option, so that the corporation was not a CCPC 433
Tax Topics - General Concepts - Illegality potential illegality of an option to acquire control of a private corporation did not nullify the option, so that the corporation was not a CCPC 165

Pellerin v. The Queen, 2015 TCC 130 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(14) - Paragraph 110.6(14)(b) fetus retroactively deemed to be beneficiary on birth 69

Twomey v. The Queen, 2012 DTC 1255 [at 3739], 2012 TCC 310

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Effective Date subsequent share issuance to give effect to shareholders' intent "gave effect to the true facts" 270

Administrative Policy

20 February 2018 External T.I. 2017-0727811E5 F - Synthetic disposition

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Synthetic disposition arrangement an arrangement which eliminates all risk of loss nonetheless “appears” not to be a synthetic disposition arrangement if there is 20% profits participation 256

7 October 2016 APFF Roundtable Q. 9, 2016-0652921C6 F - Résidence - actif utilisé / Residence - asset used

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7 October 2016 APFF Roundtable Q. 11, 2016-0652941C6 F - Contrat de location / Capital lease

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation FMV of rights under a lease must be included 134

17 July 2013 External T.I. 2012-0473261E5 F - Actif d'impôts futurs / Future income tax assets

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation tax receivable arising from carryback of NCL is active business asset cf. future tax asset 180

11 October 2013 APFF Roundtable, 2013-0495631C6 F - Actions admissibles de petites entreprises

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation 90% is generally a safe harbour, and in a particular context CRA may accept lower than 90% 119

7 October 2013 External T.I. 2013-0500941E5 F - Actif utilisé dans une entreprise active

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10 May 2013 External T.I. 2012-0449651E5 F - SENC - revenu d'entreprise exploitée activement

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 129 - Subsection 129(6) Norco followed 31

2003 APFF Roundtable Q. 7, 2003-0030045 -

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7 March 2002 External T.I. 2001-009178 -

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4 July 1997 Technical Interpretation 5-9636

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12 April 1994 T.I. (C.T.O. "Active Assets")

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5 May 1994 T.I. 933027

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14 February 1994 External T.I. 5-933040 -

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9 August 1994 T.I. 9333125

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1994 A.P.F.F. Round Table, Q. 35

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93 C.R. - Q. 58

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9 February 1993 T.I. (Tax Window, No. 29, p. 3 ¶2436)

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13 January 1993 T.I. 923260 (November 1993 Access Letter, p. 504, ¶C109-156)

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2 December 1992 T.I. (Tax Window, No. 27, p. 22. ¶2320)

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7 December 1992 T.I. (Tax Window, No. 27, p. 18, ¶2326)

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92 C.R. - Q.54

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92 C.R. - Q.24

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) 50

28 July 1992 T.I. (Tax Window, No. 21, p. 7, ¶2054)

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23 June 1992 T.I. (April 1993 Access Letter, p. 146, ¶C109-128)

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1992 A.P.F.F. Annual Conference, Q. 9 (January - February 1993 Access Letter, p. 53)

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10 January 1992 Memorandum (Tax Window, No. 17, p. 13, ¶1773)

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25 March 1992 T.I. (Tax Window, No. 18, p. 14, ¶1828)

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19 March 1992 T.I. (Tax Window, No. 18, p. 5, ¶1823)

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11 February 1992 T.I. (Tax Window, No. 16, p. 18, ¶1743)

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91 C.R. - Q.13

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91 C.R. - Q.14

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24 January 1992 T.I. (Tax Window, No. 12, p. 11, ¶1575)

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7 and 29 October 1991 T.I. (Tax Window, No. 10, p. 1, ¶1504)

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16 September 1991 TI (Tax Window, No. 9, p. 9, ¶1451)

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4 June 1991 Memorandum (Tax Window, No. 4, p. 22, ¶1276)

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15 May 1991 T.I. (Tax Window, No. 6, p. 2, ¶1357)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 186 - Subsection 186(2) 33

24 April 1991 T.I. (Tax Window, No. 2, p. 12, ¶1211)

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12 April 1991 T.I. (Tax Window, No. 2, p. 5, ¶1187)

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24 January 1991 T.I. (Tax Window, Prelim. No. 3, p. 7, ¶1106)

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23 October 1990 T.I. (Tax Window, Prelim. No. 1, p. 21, ¶1026)

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1 October 1990 T.I. (Tax Window, Prelim. No. 1, p. 15, ¶1034)

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90 C.R. - Q18

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19 March 1990 T.I. (August 1990 Access Letter, ¶1378)

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8 March 1990 T.I. (August 1990 Access Letter, ¶1379)

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8 March 1990 T.I. (August 1990 Access Letter, ¶1379)

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2 March 1990 T.I. (August 1990 Access Letter, ¶1376)

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27 February 1990 T.I. (July 1990 Access Letter, ¶1326)

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26 February 1990 T.I. (July 1990 Access Letter, ¶1327)

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20 February 1990 T.I. (July 1990 Access Letter, ¶1325)

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19 February 1990 T.I. (July 1990 Access Letter, ¶1325)

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18 January 1990 T.I. (June 1990 Access Letter, ¶1273)

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13 December 1989 T.I. (May 1990 Access Letter, ¶1227)

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15 November 89 T.I. (April 90 Access Letter, ¶1179)

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19 September 89 T.I. (February 1990 Access Letter, ¶1119)

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89 C.R. - Q.11

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October 1989 Revenue Canada Round Table - Q.12 (Jan. 90 Access Letter, ¶1075)

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88 C.R. - "Small Business Corporation Shares" - "Background"

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88 C.R. - F.Q.33

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88 C.R. - "Small Business Corporation Shares" - "Background"

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88 C.R. - F.Q. 35

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Articles

Mallin, "Organizing and Reorganizing to Ensure 'Qualified Small Business Corporation Share' Status", 1990 Canadian Tax Journal, pp. 745, 1026.

Truster, "The Capital Gains Exemption", 1989 Conference Report, c. 12.

Paragraph (c)

Subparagraph (c)(i)

Administrative Policy

11 October 2013 Roundtable, 2013-0499671C6 F - Actif d'impôts futurs / Future income tax assets

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation future income tax asset is not an asset – tax receivable is, but is an active business asset if it arose from active business 158

Share of the Capital Stock of a Family Farm or Fishing Corporation

Administrative Policy

7 October 2016 APFF Roundtable Q. 9, 2016-0652921C6 F - Résidence - actif utilisé / Residence - asset used

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Qualified Small Business Corporation Share farm house must be more than 50% used by farm employees to qualify 216

30 June 2016 External T.I. 2015-0583561E5 F - Déduction pour gain en capital - contamination

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1.1) AgriInvest accounts do not affect qualification of family farm or fishing corporations 97
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Net Income Stabilization Account Agri-Québec and AgriInvest accounts included 94

24 December 2012 External T.I. 2012-0457881E5 - Share of a capital stock of a family farm

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24 August 1995 External T.I. 5-951846 -

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92 C.R. - Q.53

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1 October 1991 T.I. (Tax Window, No. 10, p. 13, ¶1491)

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19 February 1990 T.I. (July 1990 Access Letter, ¶1328)

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Articles

Henry Shew, Jody Wong, "Multi-Level Farming Structures and the Capital Gains Exemption", Canadian Tax Focus, Vol. 6, No. 3, August 2016, p. 10

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Subsection 110.6(1.1)

Administrative Policy

30 June 2016 External T.I. 2015-0583561E5 F - Déduction pour gain en capital - contamination

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Subsection 110.6(1.3) - Property used in a farming business

Administrative Policy

9 June 2015 External T.I. 2014-0554381E5 F - Copropriété par indivision - partage de biens

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(20) retention of original acquisition date under s. 248(20)(b) 139

Paragraph 110.6(1.3)(a)

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18 June 2015 External T.I. 2015-0572791E5 F - Société de personnes agricole familiale - BAA

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Subparagraph 110.6(1.3)(a)(i)

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7 October 2016 APFF Roundtable Q. 10, 2016-0652931C6 F - Bien agricole admissible-saisine par succession

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Tax Topics - General Concepts - Ownership estate owns its property 109

Paragraph 110.6(1.3)(b)

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2 October 2015 External T.I. 2012-0463801E5 F - Déduction pour gain en capital – permis de pêche

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Paragraph 110.6(1.3)(c)

Paragraph 110.6(1.3)(c)

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13 November 2014 External T.I. 2014-0536881E5 F - Bien agricole admissible - Boisé

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Subsection 110.6(2) - Capital gains deduction — qualified farm property

Cases

Fournie v. Cromarty, 2012 DTC 5011 [at 6563], 2011 ONSC 6587

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3 February 2015 External T.I. 2015-0567231E5 - Qualified farm or fishing property

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7 January 2013 External T.I. 2012-0460791E5 - Qualified Farm Property & Oil Reserves

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24 June 1992 External T.I. 5-920895 -

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6 September 89 T.I. (February 1990 Access Letter, ¶1117)

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29 Aug. 89 T.I. (Jan. 90 Access Letter, ¶1085)

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Subsection 110.6(2.1) - Capital gains deduction — qualified small business corporation shares

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4 June 2012 External T.I. 2012-0439271E5 - QSBCS deduction by the beneficiary

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24 March 1994 T.I. 933164 (C.T.O. "Qualified Small Business Corporation Shares")

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11 January 1993 T.I. (Tax Window, No. 27, p. 14, ¶2358)

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Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) 52

18 Aug. 89 T.I. (Jan. 90 Access Letter, ¶1082)

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88 C.R. - F.Q.38

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Articles

Matthew Clark, Josh Proulx, Rami Pandher, "Hybrid Sales", Canadian Tax Highlights (Canadian Tax Foundation), Vol. 25, No. 5, May 2017, p. 4

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Subsection 110.6(3)

Administrative Policy

11 September 1992 T.I. (Tax Window, No. 23, p. 18, ¶2176)

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2 February 1990 T.I. (July 1990 Access Letter, ¶1329)

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Articles

Dunbar, "Forward Participation Share May Produce Tax-Exempt Gain With Minimal Downside Risk for Executive", Taxation of Executive Compensation and Retirement, February 1990

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Singer, "Revenue Canada Accepts Arrangements Designed to Make Capital Gains Exemption Available Under Employee Stock Purchase Plan", Taxation of Executive Compensation and Retirement, December 1989/January 1990

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Subsection 110.6(6) - Failure to report capital gain

See Also

Adams v. The Queen, 96 DTC 1737 (TCC)

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5 July 2012 Internal T.I. 2010-0388551I7 F - Fiducie - retour de sommes

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Tax Topics - Income Tax Act - Section 75 - Subsection 75(2) s. 75(2) does not apply to an estate freeze as the corp does not own its treasury shares issued to the trust 154
Tax Topics - Income Tax Act - 101-110 - Section 105 - Subsection 105(1) income distributed to daughter-in-law who in fact was not a beneficiary includible in her income under s. 105(1) but not deductible by trust under s. 104(6) 156
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(13) capital gain distributed by family trust to children and purportedly lent by them to their parents (also beneficiaries) was instead included in the parents’ income under s. 104(13) 403

93 C.R. - Q. 54

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June 1990 Meeting of Alberta Institute of Chartered Accountants (November 1990 Access Letter, ¶1499, Q. 8)

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Subsection 110.6(7) - Deduction not permitted

Administrative Policy

3 June 2014 External T.I. 2013-0503511E5 F - Discretionary Dividend Shares

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24 October 2012 Internal T.I. 2012-0456711I7 F - Inadmissibilité à la déduction pour GC

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.2) no retroactive adjustment of capital gains exemption 107
Tax Topics - Income Tax Act - Section 248 - Subsection 248(10) 43

9 March 1995 External T.I. 5-943025 -

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14 December 1992 Memorandum (Tax Window, No. 30, p. 4, ¶2488)

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10 January 1992 CGA Roundtable, Q. 19, 7-912224

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90 C.R. - Q19

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89 C.R. - Read Paper (C.18)

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Tax Topics - Income Tax Act - Section 69 - Subsection 69(11) 47

Articles

McKnight, "Hidden Problems in Selling Employee Ownership", Canadian Current Tax, October 1994, p. 7

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Subsection 110.6(8) - Deduction not permitted

Administrative Policy

8 March 1994 T.I. 932927 (C.T.O. "Capital Gains Exemption")

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17 November 1992 T.I. 903665 (September 1993 Access Letter, p. 417, ¶C109-143)

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92 C.R. - Q.56

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1992 A.P.F.F. Annual Conference, Q. 8 (January - February 1993 Access Letter, p. 53)

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1992 A.P.P.F. Annual Conference, Q. 7 (January - February 1993 Access Letter, p. 52)

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24 February 1992 T.I. (Tax Window, No. 17, p. 4, ¶1762)

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10 January 1992 Memorandum (Tax Window, No. 17, p. 13, ¶1773)

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30 November 1991 Round Table (4M0462), Q. 11.3 - Scope of Subsection: 110.6(8) of the I.T.A. (C.T.O. September 1994)

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10 and 11 July 1991 T.I. (Tax Window, No. 6, p. 11, ¶1347)

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24 June 1991 T.I. (Tax Window, No. 4, p. 2, ¶1313)

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Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) 49

15 February 1991 T.I. (Tax Window, Prelim. No. 3, p. 24, ¶1120)

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20 March 1990 T.I. (August 1990 Access Letter, ¶1380)

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21 February 1990 T.I. (July 1990 Access Letter, ¶1330)

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31 January 1990 T.I. (June 1990 Access Letter, ¶1269)

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87 C.R. - Q.60

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Articles

Brender, "The De Minimis Dividend Test Under Subsection 110.6(8)", 1993 Canadian Tax Journal, Vol. 41, No. 4, p. 808.

Subsection 110.6(9) - Average annual rate of return

Administrative Policy

11 October 2013 APFF Roundtable, 2013-0495641C6 F - Taux de rendement annuel moyen

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18 May 1994 External T.I. 5-940741 -

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14 June 1990 T.I. (November 1990 Access Letter, ¶1528)

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7 June 1990 Memorandum (November 1990 Access Letter, ¶1529)

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Subsection 110.6(14) - Related persons, etc.

Paragraph 110.6(14)(a)

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19 September 1990 T.I. (Tax Window, Prelim. No. 1, p. 14, ¶1031)

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Paragraph 110.6(14)(b)

See Also

Pellerin v. The Queen, 2015 TCC 130 (Informal Procedure)

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Tax Topics - Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Qualified Small Business Corporation Share relatedness under the 24-month test is tested only at the determination time 391

Chartier and Nadeau v. The Queen, 2008 DTC 4627, 2007 TCC 37

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13 January 2012 Internal T.I. 2011-0428371I7 - Paragraph 110.6(14)(b)

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88 C.R. - F.Q.39

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Paragraph 110.6(14)(c)

Administrative Policy

May 1991 Question and Answer for a Conference (Tax Window, No. 3, p. 17, ¶1223)

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Paragraph 110.6(14)(e)

Administrative Policy

22 March 1991 T.I. (Tax Window, No. 2, p. 22, ¶1220)

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Paragraph 110.6(14)(f)

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3 March 2014 External T.I. 2014-0519071E5 F - Période de détention de 24 mois pour AAPE

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21 November 2011 External T.I. 2011-0424331E5 - ITA 110.6(14)(f)

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92 C.R. - Q.55

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90 C.R. - Q17

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1 May 1990 T.I. (October 1990 Access Letter, ¶1473)

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88 C.R. - "Small Business Corporation Shares" - "Deemed Ownership of Shares by an Unrelated Person Prior to Issuance"

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88 C.R. - F.Q.37

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Subparagraph 110.6(14)(f)(ii)

See Also

Gillen v. The Queen, 2017 TCC 163

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Words and Phrases
use
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Tax Topics - General Concepts - Ownership test of beneficial ownership 108
Tax Topics - General Concepts - Effective Date relation-back theory applied: closing retroactively confirmed previous beneficial ownership transfer 220

Subsection 110.6(15) - Value of assets of corporations

Administrative Policy

1993 A.P.F.F. Round Table, Q.13

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Paragraph 110.6(15)(a)

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7 October 2016 APFF Financial Strategies and Financial Instruments Roundtable Q. 9, 2016-0651801C6 F - Assurance-vie à assurés multiples-110.6(15)

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation corporate-owned policy valued for SBC or QSBCS purposes at the cash surrender value even if non-shareholder lives are included 93

Finance

6 October 2017 APFF Financial Strategies and Instruments Roundtable, Q.3

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Subparagraph 110.6(15)(a)(ii)

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation corporate life insurance policy and proceeds therefrom valued at CSV until share redemption time 121

Subsection 110.6(19) - Election for property owned on February 22, 1994

See Also

McCullock-Finney (Estate) v. The Queen, 2017 TCC 103 (Informal Procedure)

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Sicurella v. The Queen, 2013 DTC 1124 [at 662], 2013 TCC 79 (Informal Procedure)

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Bullard Estate v. The Queen, 2004 DTC 2717, 2004 TCC 249

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Tax Topics - Income Tax Act - Section 45 - Subsection 45(2) 100

Administrative Policy

5 January 1996 Internal T.I. 7-952595 -

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16 February 1995 Mississauga Breakfast Seminar, Q. 2, (C.T.O. "Capital Gains Election", Fax Service Doc. No. 503120)

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16 February 1995 Mississauga Breakfast Seminar, Q. 1, (C.T.O. "Capital Gains Election", Fax Service Doc. No. 9503120)

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Subsection 110.6(20) - Application of subsection (19)

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16 February 1995 Mississauga Breakfast Seminar, Q. 3

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Subsection 110.6(31)

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3 August 2018 Internal T.I. 2018-0755351I7 - Trust claiming CG reserve

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Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(21.2) flow-through of s. 110.6 treatment respecting distributed capital gains reserve 160