(5)-(7)

Subsection 245(5) - Determination of tax consequences

See Also

1245989 Alberta Ltd. v. The Queen, 2017 TCC 51, rev'd sub nom. Wild, 2018 FCA 114

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 84.1 - Subsection 84.1(1) the use of class PUC-averaging to bump the PUC of personally-held shares was an abuse of s. 84.1 633
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) use of PUC-averaging rule to bump outside PUC was abusive 261

Subsection 245(6)

Cases

2763478 Canada Inc. v. Canada, 2018 CAF 209

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(10) 9 month separation did not avoid series 272
Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) not each transaction in series effecting an estate freeze had that objective 403
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) value shift transactions that permitted the absorption of a real gain by a paper loss abused the basic capital gains regime 297

Subsection 245(7) - Exception

Cases

S.T.B. Holdings Ltd. v. Canada, 2002 DTC 7450, 2002 FCA 386

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Words and Phrases
following

See Also

J.K. Read Engineering Ltd. v. The Queen, 2014 DTC 1216 [at 3872], 2014 TCC 309

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Words and Phrases
following
Locations of other summaries Wordcount
Tax Topics - General Concepts - Res Judicata weight of obiter depends on fulness of argument 77
Tax Topics - General Concepts - Stare Decisis weight of obiter depends on fullness of argument 77
Tax Topics - Income Tax Act - Section 161 - Subsection 161(1) interest under GAAR assessments accrued from balance due dates 52

Copthorne Holdings Ltd v. The Queen, 2007 DTC 1230, 2007 TCC 481, aff'd 2011 SCC 63

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Administrative Policy

GST/HST Memorandum 16-4 "Anti-avoidance Rules" 20 February 2015

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