Section 181.2

Subsection 181.2(3) - Capital

Cases

Autobus Thomas Inc. v. The Queen, 2000 DTC 6299 (FCA), briefly aff'd 2001 DTC 5665, 2001 SCC 64

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loan

Oerlikon Aérospatiale Inc. v. Canada, 99 DTC 5318 (FCA)

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See Also

Canadian Forest Products Ltd. v. The Queen, 2004 DTC 2869, 2004 TCC 405

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Upper Lake Shipping Ltd. v. Minister of Finance, 98 DTC 6264 (Ont CA)

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Administrative Policy

12 February 2004 Internal T.I. 2003-0027201I7 - Swaps and Part I.3 Tax

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31 December 2002 External T.I. 2002-0163545 - construction deferred revenue

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Income Tax Technical News, No. 18, 16 June 2000

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29 November 2001 Internal T.I. 2001-0106227 - PREPAID LEASE OBLIGATIONS

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3 July 2001 Internal T.I. 2001-0078917 - PARTNERSHIPS AND OVERDRAFTS PART 1.3

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IT-532 "Income Tax Act, Part I.3 - Tax on Large Corporations"

1 June 2000 Internal T.I. 2000-0006167 - LARGE CORPORATION TAX GOLD CONSIGNMENTS

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5 April 2000 Internal T.I. 1999-0015087 - CONSTRUCTION CONTRACTORS

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10 February 1997 Internal T.I. 9701277 - PURCHASE AND SALE AGREEMENT - PART I.3

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7 November 1996 External T.I. 9636805 - CICA 3860 AND LARGE CORPORATIONS TAX

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9 September 1996 External T.I. 9621855 - LARGE CORPORATIONS TAX AND AUTOMOBILE DEALERSHIPS

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8 July 1996 Internal T.I. 9617717 - LEVERAGED LEASES AND PREPAID PENSION - PART I.3

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22 February 1996 Internal T.I. 9604507 - PART I.3 - CAPITAL LEASES & CONDITIONAL SALES AGREEMENTS

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1996 Tax Executive Institute Round Table, Q. 16 (No. 9638910)

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1996 Tax Executive Institute Round Table, Q. 8 (No. 9638920)

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20 July 1995 Internal T.I. 9517946 - DEFERRED REVENUE AND LARGE CORPORATIONS TAX

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9 June 1995 Internal T.I. 9515177 - LARGE CORPORATIONS TAX HEALTH WELFARE PLAN DEFERRED

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May 1995 Tax Executive Institute Round Table, Q. 22 (C.T.O. "Part I.3, Advances")

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7 May 1995 Internal T.I. 9510220 - PART I.3, O/S CHEQUES & OVERDRAFTS

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Payment & Receipt conditional payment principle accepted 77

13 October 1994 External T.I. 9413095 - CORP.PARTNERSHIPS & PART I.3

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Revenue Canada Round Table, 1994 Alberta Conference, Q. 10 (C.T.O. "Large Corporation Tax - Foreign Exchange Gains/Losses")

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Revenue Canada Round Table TEI, 16 May 1994, Q. 6 (C.T.O. "Part I.3 Tax - Deferrred Revenue")

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Revenue Canada Round Table TEI, 16 May 1994, Q. 6

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13 May 1994 Internal T.I. 9333017 - LARGE CORPORATION TAX AND INVESTMENT TAX CREDITS

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7 December 1993 External T.I. 9332865 - LARGE CORPORATION TAX

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December 1992 B.C. Tax Executives Institute Round Table, Q. 7 (October 1993 Access Letter, p. 479)

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10 September 1992 Memorandum (Tax Window, No. 24, p. 18 ¶2194)

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92 CPTJ - Q.9

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5 August 1992 T.I. 921651 (May 1993 Access Letter, p. 207, ¶C180-138; Tax Window, No. 23, p. 16, ¶2132)

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16 March 1992 T.I. (Tax Window, No. 18, p. 14, ¶1808)

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10 March 1992 T.I. (Tax Window, No. 17, p. 22, ¶1794)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 181 - Subsection 181(3) 26

91 C.R. - Q.37

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91 C.R. - Q.36

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91 CPTJ - Q.13

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November 1991 Memorandum and 14 November 1991 T.I. (Tax Window No. 13, p. 15, ¶1582)

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25 October 1991 T.I. (Tax Window, No. 12, p. 14, ¶1553)

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18 September 1991 T.I. and 27 September 1991 T.I. (Tax Window, No. 9, p. 14, ¶1454)

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8 July 1991 T.I. (Tax Window, No. 5, p. 6, ¶1329)

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10 June 1991 T.I. (Tax Window, No. 4, p. 26, ¶1294)

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5 June 1991 T.I. (Tax Window, No. 4, p. 25, ¶1281)

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Articles

Anthony Schiefer, "Buyer Beware - Structuring to Minimize to Minimize Capital Tax Consequences of a Share Purchase", Corporate Structures in Groups, Vol. IV. No. 1, p. 300

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Harris, "Developments in Asset-backed Financing: Tax Considerations", Business Vehicles, Vol. III, No. 3, 1997, p. 136

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Paragraph 181.2(3)(a)

Administrative Policy

2 May 2017 External T.I. 2016-0663781E5 F - Meaning of retained earnings/calculation of capital

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 181 - Subsection 181(3) - Paragraph 181(3)(b) - Subparagraph 181(3)(b)(i) GAAP meant ASPE if ASPE followed by the corporation 153

Paragraph 181.2(3)(c)

Cases

ADP Canada Co.(Canadian Automatic Data Processing Services Ltd.) v. Canada, 2009 DTC 5091, 2009 FCA 117

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Paragraph 181.2(3)(g)

Administrative Policy

14 April 2010 Internal T.I. 2009-0347511I7 F - Partie I.3 - Société de personnes

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation Quebec government is a corporation 34

Subsection 181.2(4) - Investment allowance

Cases

Federated Co-Operatives Ltd. v. Canada, 2001 DTC 5414, 2001 FCA 23

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See Also

Federated Co-operatives Ltd. v. The Queen, 2000 DTC 1946 (TCC), aff'd supra.

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TransCanada Pipelines Ltd. v. Minister of Revenue (1992), 62 O.A.C. 105

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Administrative Policy

14 November 2000 Internal T.I. 2000-005117 - INVESTMENT ALLOWANCE COMBINED SURPLUS

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21 March 2001 Internal T.I. 2000-0056297 - TENANT INDUCEMENT INVESTMENT ALLOWANCE

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IT-532 "Income Tax Act, Part I.3 - Tax on Large Corporations"

22 February 1996 Internal T.I. 9604507 - PART I.3 - CAPITAL LEASES & CONDITIONAL SALES AGREEMENTS

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9 January 1996 Ministerial Correspondence 952924A - CASH CONCENTRATION ACCOUNTS & PART I.3

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10 August 1995 External T.I. 9518455 - STRIPPED BONDS - ELIGIBLE FOR INVESTMENT ALLOWANCE?

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27 June 1994 External T.I. 9410195 - LARGE CORPORATION TAX & CONDITIONAL SALES CONTRACTS

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Revenue Canada Round Table TEI, 16 May 1994, Q. 6 (C.T.O. "Part I.3 Tax - Deferred Revenue")

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93 CPTJ - Q.15

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December 1992 B.C. Tax Executives Institute Round Table, Q. 7 (October 1993 Access Letter, p. 479)

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27 September 1991 T.I. (Tax Window, No. 11, p. 21, ¶1510)

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27 September 1991 T.I. (Tax Window, No. 10, p. 19, ¶1486)

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25 June 1990 T.I. (November 1990 Access Letter, ¶1544)

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Paragraph 181.2(4)(b)

Administrative Policy

25 March 2002 T.I.

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Paragraph 181.2(4)(d.1)

Administrative Policy

21 February 1994 External T.I. 9333035 - INVESTMENT ALLOWANCE - LARGE CORPORATIONS TAX

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