Subsection 143.3(2) - Options — limitation
Articles
Chris Falk, Stefanie Morand, Brian O'Neill, "Is there Always Certainty Regarding Tax Basis? – Limitations on Expenditures Pursuant to Sections 143.3 and 143.4", 2014 Conference Report, (Canadian Tax Foundation),14:1-36
Denial of cost of property acquired with options (p. 14:7)
[O]ne of the effects of section 143.3 is that the issuer will not have any cost for...
Subsection 143.3(3) - Corporate shares — limitation
Administrative Policy
2017 Ruling 2017-0699201R3 - Cross-border Butterfly
CRA ruled on a cross-border butterfly which entailed assets of the “Transferred Business” being transferred indirectly to a wholly-owned...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Distribution | cross-border butterfly with 4-party exchange and preceding distribution of DC to foreign parent to qualify as permitted exchange/rental property valued at nil/post-butterfly equaling cash payment | 1140 |
| Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Permitted Exchange - Paragraph (b) | cross-border butterfly including preliminary transfer of DC to foreing parent to come within “permitted exchange” | 444 |
| Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base | full cost of property acquired under 4-party exchange | 222 |
| Tax Topics - Income Tax Act - Section 212.1 - Subsection 212.1(1.1) - Paragraph 212.1(1.1)(b) | application on 4-party exchange | 291 |
Paragraph 143.3(3)(a)
Administrative Policy
2009 Ruling 2008-0300102R3 - Deductibility of interest
ACO, a public corporation, issues Notes the interest on which may at ACO's option be satisfied by issuing preferred shares with an aggregate...
Articles
Chris Falk, Stefanie Morand, Brian O'Neill, "Is there Always Certainty Regarding Tax Basis? – Limitations on Expenditures Pursuant to Sections 143.3 and 143.4", 2014 Conference Report, (Canadian Tax Foundation),14:1-36
Whether share issuance for debt cancellation entails ‘property transferred…to" the corporation (p. 9)
In the context of subsections 143.3(3)...
Paragraph 143.3(3)(b)
Administrative Policy
29 November 2016 CTF Roundtable Q. 3, 2016-0670201C6 - Agnico-Eagle Mines Decision
CRA rejected the suggestion that Agnico-Eagle could support the realization of a capital loss under s. 39(2) when a U.S.-dollar denominated...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 39 - Subsection 39(2) | Agnico-Eagle analysis rejected | 139 |
15 April 2009 Internal T.I. 2008-0301171I7 F - 7(3)b) vs 143.3(3)
Pubco (a Canadian public corporation) issues stock options (the “Options”) to certain employees with an exercise price not less than the FMV...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(3) - Paragraph 7(3)(b) | recognition of compensation expense under GAAP on granting and then exercise of conventional Pubco options precluded by s. 7(3)(b) and notwithstanding Alcatel | 160 |
Subsection 143.3(5) - Clarification
Paragraph 143.3(5)(b)
Articles
Chris Falk, Stefanie Morand, Brian O'Neill, "Is there Always Certainty Regarding Tax Basis? – Limitations on Expenditures Pursuant to Sections 143.3 and 143.4", 2014 Conference Report, (Canadian Tax Foundation),14:1-36
Excess is of cost over FMV (p. 6)
Implicit in the [Finance] technical note statements is the assumption that, for purposes of paragraph...