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

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Words and Phrases
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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. 2003-002720 -

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31 December 2002 External T.I. 2002-016354 -

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

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29 November 2001 Internal T.I. 2001-010622 -

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3 July 2001 Internal T.I. 2001-007891 -

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 181 - Subsection 181(3) 113

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

1 June 2000 Internal T.I. 2000-000616 -

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5 April 2000 Internal T.I. 1999-001508 -

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10 February 1997 Internal T.I. 7-970127 -

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7 November 1996 External T.I. 5-963680 -

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9 September 1996 External T.I. 5-962185 -

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8 July 1996 Internal T.I. 7-961771 -

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 181 - Subsection 181(3) 76

22 February 1996 Memorandum 960450 (C.T.O. "Part I.3 - Capital Leases and 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 Memorandum 951794 (C.T.O. "Deferred Revenue and Large Corporations Tax")

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9 June 1995 Memorandum 951517 (C.T.O. "Large Corporations Tax Health Welfare Plan")

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

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May 1995 Tax Executive Institute Round Table, Q. 22 (C.T.O. "Part I.3, O/S Cheques & Overdrafts")

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Tax Topics - General Concepts - Payment & Receipt conditional payment principle accepted 52

13 October 1994 T.I. 941309 (C.T.O. "Corp. Partnerships and Part I.III")

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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 Memorandum 933301 (C.T.O. "Large Corporation Tax and Investment Tax Credits")

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10 January 1994 T.I. 933286 (C.T.O. "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) 24

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 143

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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Words and Phrases
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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. 2000-005629 -

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

22 February 1996 Memorandum 960450 (C.T.O. "Part I.3 - Capital Leases and Conditional Sales Agreements")

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9 January 1996 T.I. 952924 (C.T.O. "Cash Concentration Accounts and Part I.3")

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10 August 1995 T.I. 951845 (C.T.O. "Stripped Bonds - Eligible for Investment Allowance?")

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27 June 1994 T.I. 941019 (C.T.O. "Large Corporations 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 T.I. 933303 (C.T.O. "Investment Allowance-Large Corporations Tax")

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