Section 256

Table of Contents

Subsection 256(1) - Associated corporations

Paragraph 256(1)(a)

Cases

The Queen v. W. Ralston & Co., 96 DTC 6488 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Harvard International Resources Ltd. v. Provincial Treasurer of Alberta, 93 DTC 5254 (Alta. Q.B.)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

The Queen v. Imperial General Properties Ltd., 85 DTC 5500, [1985] 2 CTC 299, [1985] 2 S.C.R. 288

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Allied Farm Equipment Ltd. v. MNR, 73 DTC 5036, [1972] CTC 619 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Donald Applicators Ltd. v. MNR, 69 DTC 5122, [1969] CTC 98 (Ex Ct), briefly aff'd 71 DTC 5202, [1971] CTC 402 (SCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Minister of National Revenue v. Dworkin Furs (Pembroke) Ltd. et al., 67 DTC 5035, [1967] CTC 50, [1967] S.C.R. 223

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

See Also

Kruger Wayagamack Inc. v. The Queen, 2015 DTC 1112 [at 667], 2015 TCC 90, aff'd 2016 FCA 192

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - General Concepts - Fair Market Value - Shares non-assignable put right ignored 90
Tax Topics - Income Tax Act - Section 251 - Subsection 251(2) - Paragraph 251(2)(b) - Subparagraph 251(2)(b)(i) de jure control requires strategic control, not merely operational control 83
Tax Topics - Income Tax Act - Section 256 - Subsection 256(1.2) - Paragraph 256(1.2)(c) effect of s. 256(1.2)(g) is as if company were run by 3rd party 236
Tax Topics - Income Tax Act - Section 256 - Subsection 256(5.1) de facto control requires strategic control, not merely operational control 200

Administrative Policy

1 February 1999 T.I. 982371

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

23 June 1995 T.I. 951047 (C.T.O. "Associated Corporations")

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

1993 APFF Roundtable, Q.1

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph 256(1)(b)

Cases

Southside Car Market Ltd. v. The Queen, 82 DTC 6179, [1982] CTC 214 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

The Queen v. Mars Finance Inc., 80 DTC 6207, [1980] CTC 216 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

H.A. Fawcett & Son, Ltd. v. The Queen, 80 DTC 6195, [1980] CTC 293 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

International Iron & Metal Co. Ltd. v. Minister of National Revenue, 72 DTC 6205, [1972] CTC 242, [1974] S.C.R. 898, aff'g 69 DTC 5445, [1969] CTC 668 (Ex Ct)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
control

Minister of National Revenue v. Consolidated Holding Co., 72 DTC 6007, [1972] CTC 18, [1974] S.C.R. 419

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Vina-Rug (Canada) Limited v. Minister of National Revenue, 68 DTC 5021, [1968] CTC 1, [1968] S.C.R. 193

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
group of persons group

Vineland Quarries and Crushed Stone Ltd. v. MNR, 66 DTC 5092, [1966] CTC 69 (Ex Ct), briefly aff'd 67 DTC 5283 (SCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - General Concepts - Ownership 48

Yardley Plastics of Canada Ltd. v. MNR, 66 DTC 5183, [1966] CTC 215 (Ex Ct)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
group of persons

See Also

Quincaillerie Brassard Inc. v. MNR, 91 DTC 559 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Express Cable Television Ltd. v. MNR, 82 DTC 1431 (TRB)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

King George Hotels Ltd. v. MNR, 68 DTC 635 (TAB)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Buckerfield's Ltd. v. MNR, 64 D.T.C 5301 (Ex Ct)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
control

Administrative Policy

5 April 1995 External T.I. 5-941474 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

80 C.R. - Q.25

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

IT-64R3 "Corporations

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph 256(1)(c)

Cases

1056 Enterprises Ltd. v. The Queen, 89 DTC 5287 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

See Also

Disher-Winslow Products Ltd. v. MNR, 52 DTC 27 (TAB)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
owner
Locations of other summaries Wordcount
Tax Topics - General Concepts - Ownership 168

Paragraph 256(1)(d)

Cases

Allied Farm Equipment Ltd. v. MNR, 73 DTC 5036, [1972] CTC 619 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

1056 Enterprises Ltd. v. The Queen, 89 DTC 5287 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Holiday Luggage Mfg. Co. Inc. v. The Queen, 86 DTC 6601, [1987] 1 CTC 23 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

Paragraph 256(1)(e)

Cases

The Queen v. B.B. Fast & Sons Distributors, 86 DTC 6106, [1986] 1 CTC 299 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Atomic Truck Cartage Ltd. v. The Queen, [1985] 2 CTC 21 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

The Queen v. Mars Finance Inc., 80 DTC 6207, [1980] CTC 216 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

Subsection 256(1.1)

Administrative Policy

20 February 1996 T.I. 960508 (C.T.O. "Stock Dividend Shares those of a Specified Class?")

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

31 October 1991 T.I. (Tax Window, No. 12, p. 13, ¶1560)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

3 September 1991 T.I. (Tax Window, No. 8, p. 3, ¶1437)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 256(1.2) - Control, etc.

Cases

9044 2807 Québec Inc. v. Canada, 2004 DTC 6636, 2004 FCA 23

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 256 - Subsection 256(5.1) situs of decision-making power 256

Administrative Policy

89 C.R. - Q.14

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

88 C.R. - Q.39

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph 256(1.2)(a)

Paragraph 256(1.2)(b)

Paragraph 256(1.2)(c)

See Also

Kruger Wayagamack Inc. v. The Queen, 2015 DTC 1112 [at 667], 2015 TCC 90, aff'd 2016 FCA 192

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - General Concepts - Fair Market Value - Shares non-assignable put right ignored 90
Tax Topics - Income Tax Act - Section 251 - Subsection 251(2) - Paragraph 251(2)(b) - Subparagraph 251(2)(b)(i) de jure control requires strategic control, not merely operational control 83
Tax Topics - Income Tax Act - Section 256 - Subsection 256(1) - Paragraph 256(1)(a) de jure or de facto control requires strategic control, not merely operational control 314
Tax Topics - Income Tax Act - Section 256 - Subsection 256(5.1) de facto control requires strategic control, not merely operational control 200

Administrative Policy

29 June 1995 T.I. 951064 (C.T.O. "Cotrustees of Different Trusts Same Persons")

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph 256(1.2)(d)

Paragraph 256(1.2)(f)

Cases

Canada v. Propep Inc., 2010 DTC 5088 [at 6882], 2009 FCA 274

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
beneficiary

Administrative Policy

Subparagraph 256(1.2)(f)(ii)

See Also

Moules Industriels (C.H.F.G.) Inc. v. The Queen, 2018 TCC 85

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(1) Quebec trusts are considered to be owners of their property for ITA purposes 212

Administrative Policy

14 September 2017 External T.I. 2017-0685121E5 F - Associated corporations

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 256 - Subsection 256(2) - Paragraph 256(2)(b) - Subparagraph 256(2)(b)(ii) election under s. 256(2)(b)(ii) busts s. 256(2)(a) transitivity but not association with 3rd corporation 294
Tax Topics - Income Tax Act - Section 125 - Subsection 125(5.1) making s. 256(2)(b)(ii) election, by eliminating s. 256(2)(a) transitivity, reduces the reduction for taxable capital employed in Canada 252

8 December 2015 External T.I. 2015-0608781E5 F - Associated corporations - discretionary trust

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 256 - Subsection 256(1.3) no double-counting of shares in applying s. 256(1.3) to shares deemed to be owned by minor trust beneficiaries 135

6 January 2004 External T.I. 2003-0052261E5 - Subparagraph 256(1.2)(f)(ii)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 256(1.3) - Parent deemed to own shares

Administrative Policy

8 December 2015 External T.I. 2015-0608781E5 F - Associated corporations - discretionary trust

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 256 - Subsection 256(1.2) - Paragraph 256(1.2)(f) - Subparagraph 256(1.2)(f)(ii) beneficiary includes beneficially entitled/combined application of 256(1.2)(f)(ii) and 256(1.3), but shares attributed only once] 557

8 December 2015 External T.I. 2015-0610921E5 F - Associated corporations - child under 18

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

13 October 2000 External T.I. 2000-003891 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

4 March 1994 T.I. 932874 (C.T.O. "Associated Corporations")

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

21 August 1992 T.I. 921988 (April 1993 Access Letter, p. 155, ¶C248-133)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 256(1.4) - Options and rights

Administrative Policy

16 March 2011 External T.I. 2010-0380571E5 F - Application de 251(5)b)(ii) et 256(1.4)b)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

24 July 1998 T.I. 980787

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

18 June 1998 T.I. 980570

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

5 February 1993 T.I. (Tax Window, No. 28, p. 3, ¶2411)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

91 C.R. - Q.11

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

20 April 1990 T.I. (September 1990 Access Letter, ¶1440)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph 256(1.4)(a)

Administrative Policy

7 October 2016 APFF Roundtable Q. 7, 2016-0652971C6 F - Paragraph 251(5)(b) and subsection 256(1.4)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 251 - Subsection 251(5) - Paragraph 251(5)(b) - Subparagraph 251(5)(b)(ii) may include right arising after triggering of event over which no control 266
Tax Topics - Income Tax Act - Section 251 - Subsection 251(5) - Paragraph 251(5)(b) - Subparagraph 251(5)(b)(i) right to find 3rd party purchaser 70

Subsection 256(2) - Corporations associated through a third corporation

Administrative Policy

10 December 1993 External T.I. 5-933554 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

16 June 1993 T.I. (Tax Window, No. 32, p. 12, ¶2607)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

6 September 1991 T.I. (Tax Window, No. 9, p. 6, ¶1447)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

30 March 1990 Memorandum (August 1990 Access Letter, ¶1395)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2 November 89 T.I. (April 90 Access Letter, ¶1181)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

88 C.R. - F.Q.40

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph 256(2)(b)

Subparagraph 256(2)(b)(ii)

Administrative Policy

14 September 2017 External T.I. 2017-0685121E5 F - Associated corporations

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 256 - Subsection 256(1.2) - Paragraph 256(1.2)(f) - Subparagraph 256(1.2)(f)(ii) Childco associated with Parent-controlled corp whose non-voting equity is held by family trust 83
Tax Topics - Income Tax Act - Section 125 - Subsection 125(5.1) making s. 256(2)(b)(ii) election, by eliminating s. 256(2)(a) transitivity, reduces the reduction for taxable capital employed in Canada 252

Subsection 256(2.1) - Anti-avoidance

Cases

Les installations de l'Est Inc. v. The Queen, 91 DTC 5185 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Maritime Forwarding Ltd v. The Queen, 88 DTC 6114, [1988] 1 CTC 186 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - General Concepts - Purpose/Intention 43

Kencar Enterprises Ltd. v. The Queen, 87 DTC 5450, [1987] 2 CTC 246 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Alpha Forming Corp. Ltd. v. The Queen, 83 DTC 5021, [1982] CTC 425 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

The Queen v. Covertite Ltd., 81 DTC 5363, [1981] CTC 464 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Honeywood Ltd. v. The Queen, 81 DTC 5066, [1981] CTC 38 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence 86

Lenco Fibre Canada Corp. v. The Queen, 79 DTC 5292, [1979] CTC 374 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Decker Contracting Ltd. v. The Queen, 79 DTC 5001, [1979] CTC 838 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Debruth Investments Ltd. v. M.N.R., 75 DTC 5012, [1975] CTC 55 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

First Pioneer Petroleums Ltd. v. MNR, 74 DTC 6109, [1974] CTC 108 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

See Also

Maintenance Euréka Ltée v. The Queen, 2011 DTC 1319 [at 1812], 2011 TCC 307

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Taber Solids Control (1998) Ltd. v. The Queen, 2009 DTC 1899, 2009 TCC 527

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

LJP Sales Agency Inc. v. The Queen, 2004 DTC 2007, 2003 TCC 851

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Saratoga Building Corp. v. MNR, 93 DTC 564 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

2013 Ruling 2013-0498961R3 - Partner creating a professional corporation

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Specified partnership income professional partner services corp 304

84 C.R. - Q.87

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 256(3) - Saving provision

Subsection 256(5.1) - Control in fact

Cases

Aeronautic Development Corporation v. Canada, 2018 FCA 67

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
supply contract
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) sole customer under single contract dominated the company 302

McGillivray Restaurant Ltd. v. Canada, 2016 FCA 99

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Certainty subjective interpretive tests to be avoided 66

Plomberie J.C. Langlois inc. v. Canada, 2007 DTC 5662, 2006 FCA 113

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

9044 2807 Québec Inc. v. Canada, 2004 DTC 6636, 2004 FCA 23

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Lanester Sales Ltd. v. The Queen, 2003 DTC 997 (TCC), aff'd 2004 DTC 6461, 2004 FCA 217

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) franchise arrangement was arm's length 76

Silicon Graphics Ltd. v. Canada, 2002 DTC 7113, 2002 FCA 260

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

See Also

Aeronautic Development Corporation v. The Queen, 2017 TCC 39

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Kruger Wayagamack Inc. v. The Queen, 2015 DTC 1112 [at 667], 2015 TCC 90, aff'd 2016 FCA 192

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - General Concepts - Fair Market Value - Shares non-assignable put right ignored 90
Tax Topics - Income Tax Act - Section 251 - Subsection 251(2) - Paragraph 251(2)(b) - Subparagraph 251(2)(b)(i) de jure control requires strategic control, not merely operational control 83
Tax Topics - Income Tax Act - Section 256 - Subsection 256(1) - Paragraph 256(1)(a) de jure or de facto control requires strategic control, not merely operational control 314
Tax Topics - Income Tax Act - Section 256 - Subsection 256(1.2) - Paragraph 256(1.2)(c) effect of s. 256(1.2)(g) is as if company were run by 3rd party 236

Solutions MindReady R&D Inc. v. The Queen, 2015 TCC 17

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

McGillivray Restaurant Ltd. v. The Queen, 2015 DTC 1030 [at 134], 2014 TCC 357, aff'd supra

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Lyrtech RD Inc. v. The Queen, 2013 DTC 1147 [at 820], 2013 TCC 12, aff'd 2014 FCA 267

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 251 - Subsection 251(5) - Paragraph 251(5)(b) s. 248(25) does not apply for s. 251(5)(b) purposes 294

Taber Solids Control (1998) Ltd. v. The Queen, 2009 DTC 1899, 2009 TCC 527

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Brownco Inc. v. The Queen, 2008 DTC 2591, 2008 TCC 58

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) "free" terms indicative of non-arm's length 43

Corpor-Air Inc. v. The Queen, 2007 DTC 841, 2006 TCC 75

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence 55

Avotus Corporation v. The Queen, 2007 DTC 215, 2006 TCC 505

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Plomberie J.C. Langlois Inc. c. La Reine, 2006 DTC 2997, 2004 TCC 734, aff'd supra.

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

L.d.g. 2000 Inc. v. The Queen, 2003 DTC 827 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Transport M.l. Couture v. The Queen, 2003 DTC 817 (TCC), aff'd sub. nom. 9044-2807 supra.

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Miller, The Estate of Carl Edward v. The Queen, 2002 DTC 1228 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Mimetix Pharmaceuticals Inc. v. The Queen, 2001 DTC 1026 (TCC), briefly aff'd 2003 DTC, 2003 FCA 106

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Multiview Inc. v. The Queen, 97 DTC 1489 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Rolka v. MNR, 62 DTC 1394, [1962] CTC 637 (Ex Ct)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

5 January 2016 External T.I. 2015-0568911E5 F - MRC - Revenu d’entreprise

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(d.5) Quebec regional county municipality is municipality 137

11 October 2013 APFF Roundtable, 2013-0495811C6 F - De Facto Control

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

11 October 2013 APFF Roundtable, 2013-0493651C6 F - Affiliated persons and de facto control

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.61) exception unavailable for inter vivos trust 169

23 June 1995 T.I. 951047

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

20 March 1995 T.I. 942429

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

1 September 1994 External T.I. 5-950392 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

28 July 1994 T.I. 941745

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

91 C.R. - Q.9

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

A.P.F.F. 1990 Round Table, Question 36, No. 9317770

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

20 March 1995 T.I. 942429 (C.T.O. "256(5.1) Control and Governing Bodies")

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

12 August 1992 T.I. 921604 (April 1993 Access Letter, p. 155, ¶C248-134; Tax Window, No. 23, p. 12, ¶2130)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

29 July 1992 Memorandum (Tax Window, No. 21, p. 4, ¶2037)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 249 - Subsection 249(4) 89

29 July 1992 Memorandum (Tax Window, No. 21, p. 1, ¶2038)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 85 - Subsection 85(4) 79

29 June 1992 Internal T.I. 7-920444 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 249 - Subsection 249(4) 8

91 C.R. - Q.12

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 249 - Subsection 249(4) 21

20 September 1990 Internal T.I. 7-902376 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

3 January 1990 T.I. 5-9256 (Tax Window Files "'Meaning of Canadian-Controlled Private Corporation' - Control Test"

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

22 September 89 T.I. (February 1990 Access Letter, ¶1130)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

89 C.R. - Q.15

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

3 Aug. 89 T.I. (Jan. 90 Access Letter, ¶1086)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

88 C.R. - Q.41

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Gouin-Toussaint, September 1989 Revenue Canada Round Table (Dec. 89 Access Letter, ¶1040)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Gouin-Toussaint, September 1989 Revenue Canada Round Table (Dec. 89 Access Letter, ¶1040)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Gouin-Toussaint, September 1989 Revenue Canada Round Table (Dec. 89 Access Letter, ¶1040)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

IT-64R4 "Corporations: Association and Control (Archived) 1 November 2004

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

IT-458R "Canadian-Controlled Private Corporation"

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 256 - Subsection 256(6) 0

Articles

Boriana Christov, "De Facto Control", Tax Topics, No. 1978, 4 February 2010, p. 1.

Kroft, "Meaning of de facto Control - Emerging Income Tax Issues", 1991 Conference Report, p. 8:42.

Subsection 256(6) - Idem [Control in fact]

Cases

Silicon Graphics Ltd. v. Canada, 2002 DTC 7113, 2002 FCA 260

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

4 February 2015 External T.I. 2015-0565741E5 - Canadian-controlled private corporation

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract indemnity agreement was not "indebtedness" 23
Tax Topics - Income Tax Act - Section 251 - Subsection 251(5) - Paragraph 251(5)(b) s. 256(5)(b) applied to acquisition right upon default under indemnity 153

IT-458R "Canadian-Controlled Private Corporation"

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 256 - Subsection 256(5.1) 0

Subsection 256(6.1) - Simultaneous control

Administrative Policy

30 May 1997 External T.I. 2000-0037965 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 256(7) - Acquiring control

Paragraph 256(7)(a)

Administrative Policy

22 August 2014 External T.I. 2014-0540751E5 F - Acquisition of control

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 251 - Subsection 251(2) - Paragraph 251(2)(b) - Subparagraph 251(2)(b)(iii) cousins part of related control group while fathers alive 232

12 December 2013 External T.I. 2013-0484031E5 - Application of clause 256(7)(a)(i)(B)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2011 Ruling 2010-0360921R3 - Change of trustee - control

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

22 March 2005 External T.I. 2005-0111811E5 - Acquisition of Control

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

12 August 1994 External T.I. 5-941238 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

22 January 1993 T.I. (Tax Window, No. 28, p. 10, ¶2379)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

23 March 1992 T.I. 913478 (April 1993 Access Letter, p. 156, ¶C248-135)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

90 C.R. - Q44

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

90 C.R. - Q41

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

26 February 1990 T.I. (July 1990 Access Letter, ¶1350)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

89 C.R. - Q.16

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 249 - Subsection 249(4) 155

October 1989 Revenue Canada Round Table - Q.25 (Jan. 90 Access Letter, ¶1075)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

87 C.R. - Q.66

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

81 C.R. - Q.47

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 111 - Subsection 111(5.1) 36

Paragraph 256(7)(i)

Articles

Elie Roth, Tim Youdan, Chris Anderson, Kim Brown, "Taxation of Trusts Resident in Canada", Chapter 3 of Canadian Taxation of Trusts, (Canadian Tax Foundation), 2016.

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 108 - Subsection 108(3) 374
Tax Topics - Income Tax Act - Section 251.1 - Subsection 251.1(4) - Paragraph 251.1(4)(d) 437
Tax Topics - Income Tax Act - Section 251.1 - Subsection 251.1(1) - Paragraph 251.1(1)(g) - Subparagraph 251.1(1)(g)(ii) 115
Tax Topics - Income Tax Act - Section 164 - Subsection 164(6) 141
Tax Topics - Income Tax Act - Section 112 - Subsection 112(3.2) 331
Tax Topics - Income Tax Act - 101-110 - Section 107 - Subsection 107(1) 144
Tax Topics - Income Tax Act - Section 251.2 - Subsection 251.2(3) - Paragraph 251.2(3)(b) 112
Tax Topics - Income Tax Act - Section 252.2 - Subsection 252.2(2) 115
Tax Topics - Income Tax Act - Section 70 - Subsection 70(6) - Paragraph 70(6)(d.1) 161
Tax Topics - Income Tax Act - Section 70 - Subsection 70(6) 1201
Tax Topics - Treaties - Income Tax Conventions - Article 29B 239
Tax Topics - Income Tax Act - Section 248 - (2)-(41) 157
Tax Topics - Income Tax Act - Section 248 - Subsection 248(8) 199
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(4) - Paragraph 104(4)(a.2) 59
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(4) - Paragraph 104(4)(a.3) 38
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(6) 174
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(6) 164
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(24) 163
Tax Topics - Income Tax Act - 101-110 - Section 105 - Subsection 105(1) 91
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(18) 49
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(7.01) 66
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(19) 311
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(13) 125
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) 144
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(2) 379

Paragraph 256(7)(b)

Administrative Policy

2014 Ruling 2014-0523221R3 - Amalgamation of mutual funds

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 111 - Subsection 111(5.5) amalgamation of two mutual fund corporations each with capital losses 127
Tax Topics - Income Tax Act - Section 69 - Subsection 69(11) amalgamation of two mutual fund corporations each with capital losses 127

S4-F7-C1 - Amalgamations of Canadian Corporations

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 100 - Subsection 100(2.1) s. 100(2.1) applies to non-qualifying amalgamation 58
Tax Topics - Income Tax Act - Section 111 - Subsection 111(12) application following amalgamation 103
Tax Topics - Income Tax Act - Section 116 - Subsection 116(1) deemed tcp following amalgamation 155
Tax Topics - Income Tax Act - Section 13 - Subsection 13(5.1) continuity of s. 13(5.1) on amalgamation 126
Tax Topics - Income Tax Act - Section 165 - Subsection 165(1) Amalco can continue objection and receive refunds 145
Tax Topics - Income Tax Act - Section 169 Amalco can continue objection 97
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(n) reserve after amalgamation 50
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Shareholder shareholder need not hold shares 82
Tax Topics - Income Tax Act - Section 251 - Subsection 251(3.1) deemed non-arm's length relationship on amalgamation 164
Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(iii) reserve after amalgamation 50
Tax Topics - Income Tax Act - Section 66.7 - Subsection 66.7(7) successoring where non-wholly owned amalgamation 85
Tax Topics - Income Tax Act - Section 69 - Subsection 69(13) no disposition of predecessor property on general principles 103
Tax Topics - Income Tax Act - Section 7 - Subsection 7(1.4) s. 87(5) not applicable 104
Tax Topics - Income Tax Act - Section 80.01 - Subsection 80.01(3) non-87 amalgamation/no FX gain 159
Tax Topics - Income Tax Act - Section 84 - Subsection 84(3) no deemed dividend to dissenter on amalgamation 81
Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) election filing by Amalco 103
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1.1) s. 87(1.1) qualifies for all s. 87 purposes 60
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1.2) successoring where non-wholly owned amalgamation 85
Tax Topics - Income Tax Act - Section 87 - Subsection 87(10) deemed listing of temporary Amalco shares 114
Tax Topics - Income Tax Act - Section 87 - Subsection 87(11) gain if high PUC is sub shares 47
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1) presumptive satisfaction of s. 87(1)(a)/dissent and squeeze-outs onside 260
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(a) new corp/deemed year end coinciding or not with acquisition of control 0
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(b) Amalco must follow predecessor's valuation method subject to truer picture doctrine 58
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(c) reserve after amalgamation 103
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(d) cost amount carryover 135
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(e.1) s. 100(2.1) applies to non-qualifying amalgamation 58
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(o) no continuity rule for non-security options 133
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(q) pre-amalgamation services 96
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2.11) loss-carry back to parent 159
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2.1) dovetailing with s. 88(1.1) 38
Tax Topics - Income Tax Act - Section 87 - Subsection 87(3.1) 328
Tax Topics - Income Tax Act - Section 87 - Subsection 87(3) PUC shifts 181
Tax Topics - Income Tax Act - Section 87 - Subsection 87(4) fractional share cash/ACB or value shift/implied non-recognition for predecessor shares 247
Tax Topics - Income Tax Act - Section 87 - Subsection 87(7) dovetailing with s. 78 and 112(12) 171
Tax Topics - Income Tax Act - Section 87 - Subsection 87(9) allocation of s. 87(9)(c)(ii) excess as parent chooses 218
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(d) late designation 106
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1.1) dovetailing with s. 87(2.1) 56
Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) partnership dissolution on amalgamation 123
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) deemed non-arm's length relationship on amalgamation 415
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) deemed non-arm's length relationship on amalgamation 323
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(14) class continuity on non-arm's length amalgamation 311
Tax Topics - Income Tax Regulations - Regulation 8503 - Subsection 8503(3) - Paragraph 8503(3)(b) pre-amalgamation services 96

Example 2

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2012 Ruling 2011-0402571R3 - De Jure Control - Debt Settlement

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 251 - Subsection 251(2) - Paragraph 251(2)(b) - Subparagraph 251(2)(b)(i) no immediate right to elect directors 245

17 February 2011 External T.I. 2010-0388081E5 - Clarification STEP Roundtable Q3 - Deemed Year End

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 249 - Subsection 249(4) 2010 STEP Roundtable Q. 3 clarification - no double acquisition 72
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(a) double year ends where acquisition of control under s. 256(7)(b)(ii) 159

7 January 2002 External T.I. 2001-006494 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

9 February 1999 T.I. 983175

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

5 April 1995 External T.I. 5-941474 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

22 August 1991 T.I. (Tax Window, No. 8, p. 4, ¶1408)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

ATR-7 (31 March 86)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Articles

Richler, "Triangular Amalgamations", March/April 1985 Canadian Tax Journal, p. 374

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 87 - Subsection 87(9) 68

Paragraph 256(7)(e)

Administrative Policy

30 July 2001 External T.I. 2001-009146 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 256(8) - Deemed exercise of right

Administrative Policy

92 C.R. - Q.23

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 256(9) - Date of acquisition of control

Cases

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

11 October 2013 APFF Roundtable, 2013-0495751C6 F - Time of an Acquisition of Control

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

4 July 1989 T.I. (Dec. 89 Access Letter, ¶1067)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.