Disposition

Cases

RCI Environnement Inc.(Centres de Transbordement et de Valorisation Nord-Sud Inc.) v. The Queen, 2008 DTC 4982, 2007 TCC 647, aff'd , 2009 DTC 5940, 2008 FCA 419

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Tax Topics - Income Tax Act - Section 152 - Subsection 152(9) 75
Tax Topics - Income Tax Act - Section 9 - Compensation Payments negotiated lump sum received for cancellation of non-compete was for diminutionin value of goodwill 59

Survivance v. Canada, 2007 DTC 5096, 2006 FCA 129

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Degeer v. Canada, 2001 DTC 5385, 2001 FCA 152

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Tax Topics - General Concepts - Ownership self-cancelling double title transfers 94

Anderson Estate v. The Queen, 95 DTC 758 (TCC)

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Stursberg v. The Queen, 93 DTC 5271 (FCA)

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Mintenko v. The Queen, 88 DTC 6537, [1989] 1 CTC 40 (FCTD)

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Johnstone v. The Queen, 88 DTC 6032, [1988] 1 CTC 48 (FCTD)

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Finochio v. The Queen, 87 DTC 5228, [1987] 1 CTC 313 (FCTD)

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De Graaf v. The Queen, 85 DTC 5280, [1985] 1 CTC 374 (FCTD)

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Hughes v. The Queen, 84 DTC 6110, [1984] CTC 101 (FCTD)

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Reilly Estate v. The Queen, 84 DTC 6001, [1984] CTC 21 (FCTD)

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Gameroff v. The Queen, 83 DTC 5013, [1982] CTC 411 (FCTD), rev'd 86 DTC 6023, [1986] 1 CTC 169 (FCA)

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See Also

Devon Canada Corporation v. The Queen, docket 2013-1066(IT)G, 2018 TCC 170

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Words and Phrases
doctrine of merger
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure payments made to target’s employees for surrendering their options on target’s acquisition were mostly deductible by it 279
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) - Subparagraph 20(1)(e)(i) quaere whether “sale” includes a sale to a 3rd party 167
Tax Topics - Income Tax Act - Section 111 - Subsection 111(5.2) stock option surrender payments of target deductible under s. 111(5.2) 63
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base "cost" implies the acquisition of an asset 163

Ellison v Sandini Pty Ltd, [2018] FCAFC 44

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Tax Topics - General Concepts - Ownership family court order requiring the transfer of a portion of a larger bloc of shares likely did not result in a change in their beneficial ownership as the shares likely were not fungible 973
Tax Topics - Income Tax Act - Section 73 - Subsection 73(1) - Paragraph 73(1)(b) subjective belief of parties that family court orders were efficacious did establish that a share transfer to a spouse occurred “because of” them 407
Tax Topics - General Concepts - Evidence a court order could not be interpreted in light of extrinsic evidence 100

Buzzoni, Executor of Kamhi Estate v. Commissioners for Revenue and Customs, [2012] UKUT 360 (Tax and Chancery Chamber)

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Fourney v. The Queen, 2012 DTC 1019 [at 2575], 2011 TCC 520

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Williams v. The Queen, 2005 DTC 1228, 2005 TCC 558

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Words and Phrases
beneficial owner
Locations of other summaries Wordcount
Tax Topics - General Concepts - Ownership 111

Morasse v. The Queen, 2004 DTC 2435, 2004 TCC 239 (Informal Procedure)

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Smedley v. The Queen, 2003 DTC 501 (TCC)

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General Electric Capital Equipment Finance Inc. v. Canada, 2002 DTC 6734, 2001 FCA 392

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Words and Phrases
novation
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Subparagraph 212(1)(b)(vii) material changes produced new obligation 175

Manrell v. The Queen, 2002 DTC 1222 (TCC), rev'd 2003 DTC 5225, 2003 FCA 128

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Barnabe Estate v. The Queen, 98 DTC 1824 (TCC)

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Quincaillerie Laberge Inc. v. The Queen, 95 DTC 155 (TCC)

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Words and Phrases
disposition
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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) amount received for loan extension 150

In re Barne Crown Ltd., [1995] 1 WLR 147 (Ch. D.)

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Words and Phrases
disposition

106443 Canada Inc. v. The Queen, 94 DTC 1663 (TCC)

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Sandner v. MNR, 93 DTC 901 (TCC)

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Foreman v. MNR, 93 DTC 7 (TCC)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 146 - Subsection 146(6) 52

Charron v. MNR, 91 DTC 81 (TCC)

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National Trust Co. v. Mead, [1990] 5 WWR 455, [1990] 2 S.C.R. 410

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Words and Phrases
novation
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Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) tests for novation 139

Niagara Air Bus Inc. v. Cameran (1989), 69 OR (2d) 717 (HCJ.)

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Scott Estate v. The Queen, 88 DTC 6012 (FCTD)

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Kirby v. Thorn EMI plc, [1987] BTC 462 (C.A.)

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Magnavox Electronics Co. Ltd. v. Hall, [1985] BTC 188 (HC), aff'd [1986] BTC 455 (C.A.)

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Anders Utkilens Rederi A/S v. Keller Bryant Transport Co. Ltd., [1985] BTC 131 (HC)

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Zim Properties Ltd. v. Procter, [1985] BTC 42 (HC)

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Greiner v. The Queen, 84 DTC 6073, [1984] CTC 92 (FCA)

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Words and Phrases
dispose

The Queen v. Harvey, 83 DTC 5098, [1983] CTC 63 (FCTD)

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Marren v. Ingles (1980), 54 TC 76, [1980] UKHL TC_54_76 (HL)

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Words and Phrases
notwithstanding

O'Brien v. Benson's Hosiery (Holdings) Ltd. (1979), 53 TC 241 (HL)

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Dobell v. The Queen, 77 DTC 5316, [1977] CTC 458 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence 19

Vauban Productions v. The Queen, 75 DTC 5371, [1975] CTC 511 (FCTD), aff'd 79 DTC 5371, [1979] CTC 262 (FCA)

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Jenkin R. Lewis & Son Ltd. v. Kerman, [1970] 3 All ER 414 (CA)

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Smith v. Lewis, [1902] 2 Ch. 667

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Administrative Policy

2017 Ruling 2016-0679281R3 - subsections 84(4.1) and 86(1)

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Tax Topics - Income Tax Act - Section 86 - Subsection 86(1) pubco spin-off of a U.S. business using s. 86 294

29 May 2018 STEP Roundtable Q. 16, 2018-0744121C6 - Impact of check the box election

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2017 Ruling 2016-0660321R3 - Reorg of REIT to simplify multi-tier structure

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 132.2 - Subsection 132.2(1) - Qualifying Exchange use of the s.132.2 merger and a renunciation of most of the units otherwise issuable on the merger in order to eliminate a REIT corporate subsidiary held through an LP and a sub-trust 919
Tax Topics - Income Tax Act - 101-110 - Section 107.4 - Subsection 107.4(2) - Paragraph 107.4(2)(a) s. 107.4 transfer of sub-trust’s assets to sister MFT trust 398
Tax Topics - Income Tax Act - Section 98 - Subsection 98(3) drop down of LP 1 into LP 2 followed by immediate s. 98(3) wind-up of LP 1 into LP 2 and GP of LP1, followed by immediate taxable sale by GP to LP 2 120
Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) no taxable benefit where wholly-owned partnership renounces the right to have consideration paid for the redemption of its shares in its limited partner (a mutual fund corporation) 309
Tax Topics - Income Tax Act - Section 132.2 - Subsection 132.2(3) - Paragraph 132.2(3)(g) - Subaragraph 132.2(3)(g)(vi) - Clause 132.2(3)(g)(vi)(C) - Subclause 132.2(3)(g)(vi)(C)(I) renunciation by subsidiary partnership of transferee MFT of units that otherwise would be issuable on the redemption of its incestuous holding in transferor MFC 217

2017 Ruling 2016-0670971R3 - Repayments of upstream loans and series test

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 90 - Subsection 90(8) - Paragraph 90(8)(a) subsequent intercorporate loans and discharges were not part of “series of loans or other transactions and repayments” 262
Tax Topics - Income Tax Act - Section 90 - Subsection 90(14) loan repayment not part of a prohibited series 139

2016 Ruling 2015-0612931R3 - Variation of trust indenture

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Tax Topics - Excise Tax Act - Section 141.01 - Subsection 141.01(2) CRA income tax ruling describes a structure for MFT trailer fees to be funded out of increased management fees to an indirect real estate subsidiary LP of the MFT 154

9 August 2016 Internal T.I. 2014-0526171I7 - Resettlement of a Trust

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Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a) constructive resettlement of trust on sale of beneficial interests therein extinguished its losses 186
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) sale of trust with losses to 3rd party was abusive 147

2016 Ruling 2015-0606771R3 - Disclaimer of trust interest

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Tax Topics - Income Tax Act - 101-110 - Section 107 - Subsection 107(2) disclaimer resulting in a rollout of estate assets under an intestacy 372
Tax Topics - Income Tax Act - 101-110 - Section 107 - Subsection 107(1) no disposition from disclaimer 91

2016 Ruling 2015-0615041R3 - Conversion of Delaware corporation to LLC

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2015 Ruling 2015-0578051R3 - Variation of trust indenture

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Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(7.1) addition of preferred units to a listed MFT’s capital 138

2015 Ruling 2014-0558831R3 - No-type of property spin-off butterfly

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Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Distribution prior drop-down of assets to Newco/split of DC manager's business/CEC proration/replacement option issuance as boot 1106
Tax Topics - Income Tax Act - Section 7 - Subsection 7(1.4) replacement stock options issued by Spinco treated as boot 108
Tax Topics - Income Tax Act - Section 86 - Subsection 86(1) new common shares with same attributes as old subject to rights of new special shares/pro rata PUC 162
Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) - Paragraph 85(1)(d) proration of CEC preliminary to butterfly 154

23 December 2014 External T.I. 2013-0487791E5 F - Période d'amortissement du revenu d'emphytéose

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Tax Topics - Income Tax Act - Section 9 - Timing sum received on granting an emphyteusis is proceeds because it is not a lease 184

S3-F9-C1 - Lottery Winnings, Miscellaneous Receipts, and Income (and Losses) from Crime

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14 February 2014 Internal T.I. 2013-0490891I7 - Revocable Living Trust

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Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(4) revocable living trust formed on initial settlement date 232

2014 Ruling 2014-0518521R3 - Issuance of a new class of units - Hedged Class

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Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(7.1) addition of FX-hedged units 144

3 January 2014 External T.I. 2013-0482081E5 - Nil value partnership units

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Tax Topics - Income Tax Act - Section 50 - Subsection 50(1) nil value partnership 117

18 December 2013 External T.I. 2013-0511101E5 F - Substantial interest - Part VI.1

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Tax Topics - Income Tax Act - Section 191 - Subsection 191(3) creation of substantial interest through redemption of special voting shares 398
Tax Topics - Income Tax Act - Section 249 - Subsection 249(4) voting rights shifted to 2nd trust with same trustees: no control change 169
Tax Topics - Income Tax Act - Section 251.2 - Subsection 251.2(2) - Paragraph 251.2(2)(a) no acquisition of control where votes pass from trust to an estate with the same individuals as executors 177

11 October 2013 APFF Roundtable, 2013-0495821C6 F - Share disposition

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Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) shares in different class with identical attributes are the same shares 215

8 February 2013 External T.I. 2012-0464131E5 F - Transfert de propriété

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11 February 2013 External T.I. 2012-0451791E5 - Disposition of trust interest

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2013 Ruling 2012-0464841R3 - Distribution by a trust

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2012 Ruling 2011-0418571R3 - Amendment to 6801(d) Plan

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 6801 - Paragraph 6801(d) amendment to add stock settlement alternative 82

2012 Ruling 2011-0403291R3 - Treaty exempt sale

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Tax Topics - Income Tax Act - Section 55 - Subsection 55(2) Treaty step-up to avoid the application of s. 55(2) to a spin-off made to effect an arm's length sale of the rump 291
Tax Topics - Treaties - Income Tax Conventions - Article 13 Treaty step-up to avoid the application of s. 55(2) to a spin-off made to effect an arm's length sale of the rump 291

2012 Ruling 2012-0451431R3 - Loss Consolidation

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a) ATR-66 elimination of debt to make Lossco solvent; roll-in/distribution out (one-day after roll in) of appreciated depreciables to use its losses 377
Tax Topics - Income Tax Act - Section 51.1 intercompany debt conversion to senior and junior note and elimination of junior note 25
Tax Topics - Income Tax Act - Section 80.01 - Subsection 80.01(4) intercompany debt conversion to senior and junior note and elimination of junior note 276

2012 Ruling 2011-0429611R3 - Variation of Trust Indenture

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(7.1) addition of preferred units 253
Tax Topics - Income Tax Act - 101-110 - Section 108 - Subsection 108(2) - Paragraph 108(2)(b) application of asset tests to sub LPs on look-through basis; special voting unit 337

2012 Ruling 2011-0410181R3 - Variation of trust indenture

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(7.1) addition of preferred units with proportionate allocation of taxable income to distributions 327
Tax Topics - Income Tax Act - 101-110 - Section 108 - Subsection 108(2) - Paragraph 108(2)(b) conversion of note to satisfy 10% test/partnership look-through 251

3 December 2012 External T.I. 2012-0457741E5 - Disposition of taxable Canadian property

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Tax Topics - Income Tax Act - Section 116 - Subsection 116(1) continuation amalgamation not a disposition 149

5 October 2012 APFF Roundtable, 2012-0451281C6 F - Usufruit étranger

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5 October 2012 APFF Roundtable, 2012-0455431C6 F - Changement de bourse

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6 May 2012 TEI Roundtable, 2012-0468931C6 - TEI Conference Q#5 Settlement Date

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8 March 2012 Internal T.I. 2010-0387961I7

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15 February 2012 External T.I. 2011-0426531E5 - Exchange of Gold Bullion for ETR

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7 October 2011 APFF Roundtable Q. 17, 2011-0412171C6 - 112(7) - Share-for-Share Exchange - 85(1)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 112 - Subsection 112(3) 96
Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) no disposition if "new" share rights identical 48

2011 Ruling 2011-0408871R3 F - Monetization

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2011 Ruling 2010-0389921R3 - New series of units - US dollar and Hedged

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(7.1) USD and hedged series 149

2010 Ruling 2010-0373801R3 - Conversion from a BV to a DC

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Tax Topics - Income Tax Act - Section 85.1 - Subsection 85.1(3) 44
Tax Topics - Income Tax Act - Section 95 - Subsection 95(4) - Direct Equity Percentage 44
Tax Topics - Income Tax Act - Section 86 - Subsection 86(1) exchange of shares in Netherlands BV for membership interests in Dutch coop qualified under s. 86 139
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Share membership interest in Dutch coop a share 131

2010 Ruling 2010-0358861R3 - Variation of trust indenture

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29 July 2009 External T.I. 2008-0297011E5 F - Conversion de participations dans une SNC

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Tax Topics - Income Tax Act - Section 97 - Subsection 97(2) s. 97(2) rollover not available if new partnerships interests exchanged for old interests are not in totality substantially distinguishable 201

2008 Ruling 2008-0272141R3 - Conversion of Delaware corporation into LLC

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Tax Topics - Treaties - Income Tax Conventions - Article 13 disposition of tcp through U.S. holdco 78

14 August 2008 External T.I. 2004-0104691E5

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20 November 2008 Internal T.I. 2008-0281411I7 - Addition of Beneficiaries

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30 March 2007 External T.I. 2006-0196641E5 - Transfer of Silver Bullion

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15 February 2007 External T.I. 2006-0214151E5 - Disposition of Partnership Interest

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2007 Ruling 2006-0213721R3 - Trust amendments to delete references to units

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2006 Ruling 2006-0177541R3 - Amendments to Debt, Conversion

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 51 - Subsection 51(1) addition of conversion right to debt followed by conversion 108

14 January 2005 External T.I. 2004-010941

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Tax Topics - General Concepts - Effective Date corporate revival has retroactive effect 40

2004 Ruling 2004-007317

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2004 Ruling 2004-0065921R3

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Tax Topics - Income Tax Act - Section 90 - Subsection 90(3) 173

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Tax Topics - Income Tax Act - Section 87 - Subsection 87(1) 93

24 February 2003 External T.I. 2002-014995

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Tax Topics - Income Tax Act - Section 116 - Subsection 116(1) 87

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September 1999 Gift Planning Symposium Round Table, Q. 2, No. 2000-M020417

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Tax Topics - General Concepts - Ownership residual interest of settlor 101

16 February 1999 T.I. 973200

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1999 Ruling 991430

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28 September 1998 T.I. 981975

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Tax Topics - Income Tax Act - Section 125.4 - Subsection 125.4(4) 24

14 July 1998 Memorandum 980847

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Income Tax Technical News, No. 14, "Changes in Terms of Debt Obligations".

22 December 1997 External T.I. 5-971957 -

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29 November 1996 T.I. 963204 (C.T.O. "Voting Trust, Is Disposition Recognized on Transfer")

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1997 Ruling 3-972613

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7 October 1997 T.I. 972427

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Tax Topics - Income Tax Act - Section 7 - Subsection 7(1.4) 26

28 January 1997 T.I. 964091

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1997 Ruling 970265 (See also 961817)

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Income Tax Technical News, No. 7, 21 February 1996 (cancelled)

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1996 Corporate Management Tax Conference Round Table, Q. 20

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1994 A.P.F.F. Round Table, Q. 5

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93 C.R. - Q. 16

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1 December 1993 Annual CTF Roundtable, Q.16, 932866

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93 C.R. - Q. 40

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93 C.M.TC - Q. 8

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15 January 1993 T.I. (Tax Window, No. 28, p. 23, ¶2371)

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2 December 1992 Memorandum (Tax Window, No. 27, p. 20, ¶2349, October 1993 Access Letter, p. 480)

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13 November 1992 T.I. 923187 (September 1993 Access Letter, p. 423, ¶C144-239)

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P-020, 15 October 1992 "Grandfathered Leases"

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2 September 1992 T.I. (Tax Window, No. 24, p. 15, ¶2185)

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92 C.R. - Q.26

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Tax Topics - Income Tax Act - Section 87 - Subsection 87(1) 64

92 C.R. - Q.10

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92 C.M.TC - Q.11

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12 June 1992 Memorandum (Tax Window, No. 21, p. 10, ¶2023)u

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8 January 1992 T.I. (Tax Window, No. 15, p. 15, ¶1688)

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91 C.R. - Q.41

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November 1991 Memorandum (Tax Window, No. 12, p. 19, ¶1562)

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29 August 1991 T.I. (Tax Window, No. 8, p. 10, ¶1424)

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21 May 1991 Memorandum (Tax Window, No. 3, p. 22, ¶1256)

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Tax Topics - Income Tax Act - Section 98 - Subsection 98(2) 91

4 January 1991 T.I. (Tax Window, Prelim. No. 3, p. 17, ¶1085)

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31 August 1990 External T.I. 5-9691 - Continuation of a Partnership

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12 September 1990 T.I. (Tax Window, Prelim. No. 1, p. 21, ¶1014)

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Tax Topics - Income Tax Act - Section 164 - Subsection 164(6) 54

9 September 1990 T.I. (Tax Window, Prelim. No. 1, p. 12, ¶1033)

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90 C.R. - Q31

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18 May 1990 T.I. (October 1990 Access Letter, ¶1470)

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Tax Topics - Income Tax Act - Section 98 - Subsection 98(3) 19

18 September 89 T.I. (February 1990 Access Letter, ¶1107)

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89 C.R. - Q.5

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October 1989 Revenue Canada Round Table - Q.7 (Jan. 90 Access Letter, ¶1075)

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9 Aug. 89 T.I. (Jan. 90 Access Letter, ¶1079)

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89 C.M.TC - Q.5

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89 C.M.TC - "Bare Trusts"

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88 C.R. - F.Q.31

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88 C.P.T.J. - Q.12

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88 C.R. - "Finance and Leasing" - "Loans of Gold and Other Commodities"

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88 C.R. - Q.33

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ATR-1 (29 Nov. 85)

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84 C.R. - Q.64

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84 C.R. - Q.80

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Tax Topics - Income Tax Act - Section 112 - Subsection 112(1) 17

81 C.R. - Q.54

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79 C.R. - Q.41

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IT-461 "Forfeited Deposits"

IT-448 "Dispositions - Changes in Terms of Securities"

IT-441 "Capital Cost Allowance - Certified Feature Productions and Certified Short Productions"

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IT-233R "Lease-Option Agreements; Sale-Leaseback Agreements"

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Tax Topics - General Concepts - Ownership 10

IT-133 "Stock Exchange Transactions - Date of Disposition of Shares"

IT-65 "Stock Splits and Consolidations"

IT-126R2, "Meaning of 'Winding-Up' ", March 20, 1995

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IC 72-17R4 "Procedures concerning the disposition of taxable Canadian property by non-residents of Canada - Section 116"

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Carrie Aiken, Johnson Tai, "Debt Restructuring Transactions – Issues, Strategies and Trends", 2016 CTF Annual Conference draft paper

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Alison Spiers, "ECP Planning: Some Practical Considerations", Canadian Tax Focus, Vol. 6, No. 4, November 2016, p 1

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Tax Topics - Income Tax Act - Section 14 - Subsection 14(1) a purported transfer of goodwill or knowhow separately from the related business may not be effective 94

Stephen Fyfe, Craig Webster, 2000 Conference Report, c. 21: Discussion of Multi-Class Mutual Fund Trusts.

Brown, "How to Spot the Difference Between Repos and Stock Loans", International Financial Law Review, June 1996, p. 51.

Kroft, "An Update on Select Legal Issues Relating to Dispositions and Exchanges of Property", 1995 Corporate Management Tax Conference Report, c. 10.

Douglas S. Ewens, Michael J. Flatters, "Toward a more Coherent Theory of Dispositions", 1995 Canadian Tax Journal, Vol. 43, No. 5, p. 1377

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Innes, Cuperfain, "Variation of Trust: An Analysis of the Effects of Variations of Trust under the Provisions of the Income Tax Act", 1995 Canadian Tax Journal, Vol. 43, No. 1, p. 16.

Joel A. Nitikman, "Rescission of Contracts for Mistake", Canadian Current Tax, April 1995, Vol. 5, No. 7, p. 63.

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Tax Topics - General Concepts - Effective Date 0

Gillespie, "Lease Financing", 1992 Corporate Management Tax Conference, c. 7

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Brown, "The Transfer of Property on Death: Ownership, Control and Vesting", 1994 Canadian Tax Journal, Vol. 42, No. 6, p. 1449.

Goodman, "Is a Settlement of Property on a Revocable Inter Vivos Trust a Disposition for Income Tax Purposes", Estates & Trusts Journal, Vol. 14, No. 2, December 1994, p. 198.

Harris, "Tax Aspects of Condominium Conversions and Lease Inducement Payments to Recipients", 1986 Conference Report, c.45.

Wilde, "Damages and Capital Gains Tax", British Tax Review, 1991, Nos. 1&2, p. 5

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Ward, Arnold, "Dispositions - A Critique of Revenue Canada's Interpretation", Canadian Tax Journal, September-October 1980, p. 559.

Paragraph (b)

Administrative Policy

16 March 2015 Internal T.I. 2013-0479861I7 - Section 116 & forfeited deposits on real property

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Tax Topics - Income Tax Act - Section 116 - Subsection 116(5) forfeited sale deposit was proceeds of security interest rather than of tcp 235
Tax Topics - Income Tax Act - Section 248 - Subsection 248(4) forfeited sale deposit was proceeds of security interest rather than of tcp 235

Paragraph (f)

Administrative Policy

2016 Ruling 2014-0552321R3 F - Trust to trust Transfer

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Tax Topics - Income Tax Act - Section 74.4 - Subsection 74.4(4) having a trust interest vest indefeasibly in a minor is consistent with the minor not receiving or having any use of the trust capital 458
Tax Topics - Income Tax Act - 101-110 - Section 108 - Subsection 108(1) - Trust - Paragraph (g) trust holding property on its 21st anniversary for minors was not subject to s. 104(4) as their shares would have been deemed under the Trust Deed to be irrevocably determined by then 397
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(5.8) 104(5.8) applied to transfer to new trust with the same beneficiaries and essentially the same terms 45

2013 Ruling 2013-0492831R3 - Trust to trust transfer of property

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2013 Ruling 2011-0395091R3 - MFC to MFT Conversion

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Paragraph (n)

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15 September 2017 External T.I. 2017-0709331E5 - Vertical absorptive foreign merger

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Tax Topics - Income Tax Act - Section 87 - Subsection 87(8) disposition at FA1 level where simultaneous aborptive merger into it of FA2 and FA3 (held by FA2) 191

4 March 2013 Internal T.I. 2012-0449371I7 - Downstream absorptive merger

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Gordon Zittlau, "Corporate Reorganizations Involving Taxable Canadian Property – Foreign Merger Considerations", International Tax Planning (Federated Press), Vol. XX, No. 3, 2015, p. 1407

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Tax Topics - Income Tax Act - Section 87 - Subsection 87(8) 332

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