Administrative Policy
20 February 2018 External T.I. 2017-0727811E5 F - Synthetic disposition
Ten months after the formation by him of a small business corporation, Mr. A agrees with an arm’s length employee of the corporation to sell 1/3...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Qualified Small Business Corporation Share | disposition could be deferred to end of 24 month period if deferred-closing agreement was not a synthetic disposition agreement | 204 |
Articles
Edward Miller, Matias Milet, "Derivative Forward Agreements and Synthetic Disposition Arrangements", 2013 Conference Report, (Canadian Tax Foundation), pp 10:1-50
Similar U.S. constructive sale proposal (p. 10:26)
Even if one were to decide that 90 percent is generally an appropriate threshold in statutory...
Ian Caines, Chris Van Loan, "Character Conversion Transactions and Synthetic Disposition Arrangements Updated", Corporate Finance, Volume XIX, No. 1, 2013, p. 219.
One-sided v. two-sided test (p. 2200)
One interesting question that is not fully resolved (but that is highlighted by the inclusion of an...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Derivative Forward Agreement | 485 |