Section 40

Table of Contents

Subsection 40(1) - General rules

Cases

Abrametz v. Canada, 2009 DTC 5828, 2009 FCA 111

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Calculating and reporting your capital gains and losses

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Tax Topics - Income Tax Act - Section 39 - Subsection 39(2) 33

Paragraph 40(1)(a)

Subparagraph 40(1)(a)(i)

Cases

Martin v. Canada, 2015 FCA 204

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Gaynor v. The Queen, 91 DTC 5288 (FCA)

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The Queen v. Demers, 86 DTC 6411, [1986] 2 CTC 321 (FCA)

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Tax Topics - Income Tax Act - Section 54 - Proceeds of Disposition 128

See Also

Rio Tinto Alcan Inc. v. The Queen, 2016 TCC 172

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees investment dealer fees incurred respecting the advisability of making hostile takeover were fully deductible under s. 9 393
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) investment dealer fees re advisability of making hostile takeover were fully deductible 515
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(cc) legal fees incurred in securing regulatory approval for a hostile bid related to the bidder's business of earning income from shares and interaffiliate sales 170
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(g) takeover bid circular costs did not qualify 96
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure fees incurred in order to acquire shares were excluded/butterfly expenses excluded as taxpayer was not in the business of implementing corporate reorganizations 343
Tax Topics - Income Tax Act - Section 169 - Subsection 169(2.1) raising general question of deductibility of fees and listing s. 20(1)(e) did not satisfy s. 165(1.11) 228
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) failure to advance evidence showing allocation of fees to share consideration 131
Tax Topics - Statutory Interpretation - French and English Version finding common meaning of 2 versions of s. 20(1)(bb) 102

Brosamler Estate v. The Queen, 2012 DTC 1193 [at 3493], 2012 TCC 204 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base probate fees added to cost 150

Avis Immobilièn G.M.B.H. v. The Queen, 94 DTC 1039 (TCC)

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Words and Phrases
expense for the purpose of

Capcount Trading v. Evans, [1993] BTC 3 (C.A.)

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Campbellton Enterprises Ltd. v. MNR, 90 DTC 1869 (TCC)

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Samson Estate v. MNR, 90 DTC 1150 (TCC)

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Bentley v. Pike, [1981] T.R. 17 (HCJ.)

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15 October 2015 Internal T.I. 2014-0527041I7 F - Disposition de biens

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for the purpose

15 September 2015 External T.I. 2015-0583221E5 F - Redemption by a cooperative of its own shares

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10 June 2013 STEP Round Table Q. 10, 2013 0480411C6 (Brosamler decision)

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Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base 75

11 January 2013 External T.I. 2012-0436771E5 - Sale of a business

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(9.1) penalty paid by shareholder 83
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) continued deduction where debt settlement by shareholder rather than taxpayer 22

29 July 2004 Internal T.I. 2003-002376 -

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9 June 2003 Internal T.I. 2003-001330 -

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21 October 1993 T.I. 9325325 [loan penalty on sale]

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26 January 1993 Memorandum (Tax Window, No. 28, p. 15, ¶2399)

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91 CR - Q.29

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18 November 1991 Memorandum (Tax Window, No. 11, p. 19, ¶1537)

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89 C.M.TC - "Leasing Costs"

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Subparagraph 40(1)(a)(iii)

Cases

Pineo v. The Queen, 86 DTC 6322, [1986] 2 CTC 71 (FCTD)

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The Queen v. Derbecker, 84 DTC 6549, [1984] CTC 606 (FCA)

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Words and Phrases
due

Neder v. The Queen, 82 DTC 6022, [1981] CTC 501 (FCA)

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Tax Topics - General Concepts - Fair Market Value - Land 64

See Also

Alguire v. The Queen, 95 DTC 532 (TCC)

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Administrative Policy

S4-F7-C1 - Amalgamations of Canadian Corporations

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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 256 - Subsection 256(7) - Paragraph 256(7)(b) realted party, majority and 50% group exceptions 448
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

24 February 2014 External T.I. 2013-0505391E5 F - Clause de earnout renversé

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(g) no capital gains reserve on reverse earn-out for a share sale 207

7 October 2013 Internal T.I. 2013-0504081I7 F - Interaction between 55(2) and 40(1)(a)(iii)

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16 November 2001 External T.I. 1999-0009295 -

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17 November 1999 T.I. 990126

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Words and Phrases
loan
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Tax Topics - Income Tax Act - Section 97 - Subsection 97(2) 108

31 March 1995 External T.I. 5-943011 -

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93 C.R. - Q. 41

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10 October 1991 T.I. (Tax Window, No. 11, p. 14, ¶1515)

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21 August 1991 T.I. (Tax Window, No. 8, p. 6, ¶1403)

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14 February 1991 T.I. (Tax Window, Prelim. No. 3, p. 12, ¶1119)

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IT-236R2 "Reserves - Dispositions of Capital Property"

IT-436R "Reserves - Where Promissory Notes are Included in Disposal Proceeds"

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Tax Topics - General Concepts - Payment & Receipt 43

Articles

Smith, "Corporate Restructuring Issues: Public Corporations", 1990 Corporate Management Tax Conference Report, pp. 6:6-6:8: discussion of claiming of reserve by vendor under a take-over bid.

Paragraph 40(1)(b)

Administrative Policy

18 August 2014 External T.I. 2014-0540361E5 F - CDA and the deeming rules of 40(3.6) or 112(3)

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Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account ss. 112(3) and 40(3.6) stop-loss rules modify operation of s. 40(1)(b) 122

Subsection 40(2) - Limitations

Paragraph 40(2)(b)

Cases

Cassidy v. Canada, 2011 FCA 271

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The Queen v. Joyner, 88 DTC 6459, [1988] 2 CTC 280 (FCTD)

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The Queen v. Yates, 83 DTC 5158, [1983] CTC 105 (FCTD), aff'd 86 DTC 6296 [1986] 2 CTC 46 (FCA)

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Tax Topics - Income Tax Act - Section 54 - Principal Residence 58

See Also

Francoeur v. Agence du revenu du Québec, 2016 QCCQ 11906

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Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate somewhat quick flip by a builder was eligible for the principal residence exemption 325

Cassidy v. The Queen, 2010 DTC 1336 [at 4287], 2010 TCC 471

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17 October 2014 Internal T.I. 2014-0546091I7 F - Indemnités lors d'une négociation de gré à gré

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7 October 2016 APFF Roundtable Q. 2, 2016-0652841C6 F - Changement partiel d’usage - immeuble locatif et résidentiel

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Tax Topics - Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(c) switch between which triplex units used for personal/family rental or 3rd-party rental did not trigger change of use 237
Tax Topics - Income Tax Act - Section 54 - Principal Residence triplex contained separate housing units 144

7 October 2016 APFF Roundtable Q. 3, 2016-0652851C6 F - Annulation d'une promesse d'achat sur une maison

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Tax Topics - Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(b) no capital loss for damages paid for breach of purchase obligation 67

10 June 2016 External T.I. 2015-0590371E5 F - Résidence principale - stationnement

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Tax Topics - Income Tax Act - Section 54 - Principal Residence - Paragraph (e) a parking space can form part of a condo housing unit 229

11 April 1995 T.I. 950740 (C.T.O. "40(2)(b)")

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16 February 1995 Mississauga Breakfast Seminar, Q. 4

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88 C.R. - Q.55

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80 C.R. - Q.24

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Paragraph 40(2)(e)

See Also

Plant National Ltd. v. MNR, 89 DTC 401 (TCC)

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12 May 1992 Memorandum 921006 (May 1993 Access Letter, p. 194, ¶C38-156)

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25 March 1991 T.I. (Tax Window, No. 1, p. 7, ¶1170)

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10 January 1990 T.I. (June 1990 Access Letter, ¶1257)

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Tax Topics - Income Tax Act - Section 84 - Subsection 84(9) 56

86 C.R. - Q.22

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Paragraph 40(2)(e.1)

Administrative Policy

2014 Ruling 2013-0479701R3 - Transfer of US dollar loan

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Tax Topics - Income Tax Act - Section 39 - Subsection 39(2) amendment of non-interest bearing loan to be interest-bearing 28
Tax Topics - Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(g) - Subparagraph 40(2)(g)(ii) s. 40(2)(e.1) trumped s. 40(2)(g)(ii) so that US Loan ACB preserved 112
Tax Topics - Income Tax Act - Section 80.01 - Subsection 80.01(3) S. 40(2)(e.1) trumped s. 40(2)(g)(ii) so that US Loan ACB preserved 167

2012 Ruling 2011-0426051R3 - Debt Restructuring

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Tax Topics - Income Tax Act - Section 80.01 - Subsection 80.01(4) ATR-66 debt tuck-under and wind-up transactions 304

Articles

Mike J. Hegedus, "Paragraph 40(2)(e.1) Versus Subparagraph 40(2)(g)(ii): Potential Conflict?", Resource Sector Taxation (Federated Press), Vol. IX, No. 4, 2014, p.684.

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Paragraph 40(2)(f)

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

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Paragraph 40(2)(g)

Subparagraph 40(2)(g)(ii)

Cases

Service v. Canada, 2005 DTC 5281, 2005 FCA 163

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Rich v. Canada, 2003 DTC 5115, 2003 FCA 38

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Byram v. Canada, 99 DTC 5117 (FCA)

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Cadillac Fairview Corp. Ltd. v. Canada, 99 DTC 5121 (FCA)

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Bosa Bros. Construction Ltd. v. The Queen, 96 DTC 6193 (FCTD)

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Brown v. The Queen, 96 DTC 6091 (FCTD)

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Smith v. The Queen, 93 DTC 5351 (FCA)

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Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) 169

The Queen v. Lalonde, 84 DTC 6159 (FCTD), aff'd 89 DTC 5286 (FCA)

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See Also

Coveley v. The Queen, 2014 DTC 1041 [at 2771], 2013 TCC 417, aff'd 2014 FCA 281

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Tax Topics - Income Tax Act - Section 50 - Subsection 50(1) bad debt claim, but business as usual 116

Audet v. The Queen, 2012 DTC 1208 [at 3556], 2012 TCC 162 (Informal Procedure)

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MacCallum v. The Queen, 2011 DTC 1225 [at 1308], 2011 TCC 316

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Scott v. The Queen, 2010 TCC 401, 2010 DTC 1273 [at 3910]

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Alessandro v. The Queen, 2007 DTC 1373, 2007 TCC 411

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Daniels v. The Queen, 2007 DTC 883, 2007 TCC 179

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Kyriazakos v. The Queen, 2007 DTC 373, 2007 TCC 66

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Tax Topics - Income Tax Act - Section 50 - Subsection 50(1) no attempt to collect was reasonable 124

Toews v. The Queen, 2005 DTC 1359, 2005 TCC 597

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Proulx-Drouin v. The Queen, 2005 DTC 487, 2005 TCC 116

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Bernier v. The Queen, 2004 DTC 3235, 2004 TCC 376

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Joncas v. The Queen, 2004 DTC 2315, 2005 TCC 647 (Informal Procedure)

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MacKay v. The Queen, 2003 DTC 748 (TCC)

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Gordon v. The Queen, 96 DTC 1554 (TCC)

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Tax Topics - Income Tax Act - Section 39 - Subsection 39(12) 79

Burns v. The Queen, 94 DTC 1370 (TCC)

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Tax Topics - Income Tax Act - Section 50 - Subsection 50(1) 109

National Developments Ltd. v. The Queen, 94 DTC 1061 (TCC)

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W.F. Botkin Construction Ltd. v. The Queen, 93 DTC 448 (TCC)

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Glass v. MNR, 92 DTC 1759 (TCC)

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Madaline v. MNR, 91 DTC 1451 (TCC)

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O'Blenes v. MNR, 90 DTC 1068 (TCC)

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Business Art Inc. v. MNR, 86 DTC 1842 (TCC)

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Administrative Policy

S4-F8-C1 - Business Investment Losses

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16 June 2016 Internal T.I. 2015-0597971I7 F - Perte réputée nulle - loss deemed nil

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Tax Topics - Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(c) BIL potentially could be recognized on a non-interest bearing loan made to a corporation in which the taxpayer had no equity 0

2014 Ruling 2013-0479701R3 - Transfer of US dollar loan

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Tax Topics - Income Tax Act - Section 39 - Subsection 39(2) amendment of non-interest bearing loan to be interest-bearing 28
Tax Topics - Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(e.1) s. 40(2)(e.1) trumped s. 40(2)(g)(ii) so that US Loan ACB preserved 167
Tax Topics - Income Tax Act - Section 80.01 - Subsection 80.01(3) S. 40(2)(e.1) trumped s. 40(2)(g)(ii) so that US Loan ACB preserved 167

6 May 2014 Internal T.I. 2014-0524651I7 - Loss on conversion

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Tax Topics - Income Tax Act - Section 51 - Subsection 51(1) s. 51 applies where issuer had a cash redemption override 200
Tax Topics - Income Tax Act - Section 51 - Subsection 51(1) conversion not under Note terms 175

6 December 2012 External T.I. 2012-0463431E5 F - Application of subparagraph 40(2)(g)(ii)

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2012 Ruling 2010-0386201R3 - Tower structure capitalized by interest-free loans

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Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(i) non-interest-bearing loans is made for income producing purposes: generating dividends 832

14 January 2004 External T.I. 2003-003875

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17 December 1996 Memorandum 963454

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Halifax Round Table, February 1994, Q. 1

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23 December 1993 T.I. 931790 (C.T.O. "Allowable Business Investment Loss")

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91 C.R. - Q.35

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21 August 1991 T.I. (Tax Window, No. 8, p. 22, ¶1397)

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12 September 1990 T.I. (Tax Window, Prelim. No. 1, p. 10, ¶1016)

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15 September 89 Memorandum (February 1990 Access Letter, ¶1105)

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1 September 89 T.I. (February 1990 Access Letter, ¶1106)

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22 Aug. 89 T.I. (Jan. 90 Access Letter, ¶1078)

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81 C.R. - Q.4

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IT-239R2 "Deductibility of Capital Losses from Guaranteeing Loans for Inadequate Consideration and from Loaning Funds at less than a Reasonable Rate of Interest in Non-arm's Length Circumstances"

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Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) 46

IT-390 "Unit Trusts - Cost of Rights and Adjustments to Cost Base"

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Tax Topics - Income Tax Act - Section 52 - Subsection 52(6) 0

Articles

Reid, "Capital and Non-Capital Losses", 1990 Conference Report, c. 16

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Subparagraph 40(2)(g)(iii)

Administrative Policy

7 October 2016 APFF Financial Strategies and Financial Instruments Roundtable Q. 2, 2016-0651711C6 F - RRIF, Transfer of designated benefit

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Tax Topics - Income Tax Act - Section 54 - Personal-Use Property land underlying duplex used 40% personally is not personal-use property 214
Tax Topics - Income Tax Regulations - Regulation 1102 - Regulation 1102(2) Reg. 1102(2) deems building to be separate from land and does not bifurcate the land 161
Tax Topics - Income Tax Act - Section 146.3 - Subsection 146.3(6.11) computation of eligible amount following year of death 285

Subsection 40(3) - Deemed gain where amounts to be deducted from adjusted cost base exceed cost plus amounts to be added to adjusted cost base

Administrative Policy

30 October 2014 External T.I. 2013-0488881E5 - Upstream Loan

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8 October 2010 Roundtable, 2010-0373461C6 F - Retrait d'une société de personnes

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Rulings Directorate Discussion and Position Paper on Motion Picture Films and Video Tapes as Tax Shelters, Version 29/3/93 930501 (C.T.O. "Motion Picture Films - C.C.A.")

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Articles

Melanie Huynh, Eric Lockwood, "Foreign Affiliates and Adjusted Cost Base", 2007 Canadian Tax Journal, Issue No. 1

Subsection 40(3.1) - Deemed gain for certain partners

Administrative Policy

27 June 2016 External T.I. 2016-0637341E5 F - Partnerships - Negative ACB

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 53 - Subsection 53(2) - Paragraph 53(2)(c) - Subparagraph 53(2)(c)(v) loan advances to a limited partner may give rise to immediate s. 53(2)(c)(v) grind 243
Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.13) retention of partnership profits not a contribution 138
Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(iv) assumption of loan can be contribution, but not retained profits 169

18 June 2014 External T.I. 2011-0417491E5 - Non-resident's partnership interest

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Subsection 40(3.13)

Administrative Policy

27 June 2016 External T.I. 2016-0637341E5 F - Partnerships - Negative ACB

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 53 - Subsection 53(2) - Paragraph 53(2)(c) - Subparagraph 53(2)(c)(v) loan advances to a limited partner may give rise to immediate s. 53(2)(c)(v) grind 243
Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.1) loans by LP to partner potentially gave rise to negative ACB gain 156
Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(iv) assumption of loan can be contribution, but not retained profits 169

Subsection 40(3.14)

Paragraph 40(3.14)(a)

Articles

Lorenzo Bonanno, Guy Buckley, "Limited Liability Partnerships", Canadian Tax Highlights, Vol. 25, No. 2, February 2017, p. 7

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Subsection 40(3.3) - When subsection (3.4) applies

Administrative Policy

3 February 2016 Internal T.I. 2015-0588791I7 - Meaning of substituted property

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6 January 2009 Internal T.I. 2008-0280111I7 -

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2007 Ruling 2007-0245281R3

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21 March 2007 External T.I. 2004-0091061E5 -

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Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.2) 47

Articles

Marc Ton-That, Rick McLean, "Navigating the Stop-Loss Rules", Corporate Structures and Groups, Vol. VI, No. 3, p. 324.

Subsection 40(3.4) - Loss on certain properties

Administrative Policy

27 October 2014 Internal T.I. 2014-0534981I7 F - Subsection 40(3.4)

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2 July 2014 External T.I. 2014-0529731E5 F - Stop-loss Rules

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28 November 2010 CTF Annual Roundtable Q. 8, 2010-0386311C6 - Subsection 40(3.4)

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6 October 2011 External T.I. 2011-0399611E5 - Subsections 40(3.3) and 40(3.4)

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2010 Conference Report CRA Round Table, Q. 8 [not carried forward to Income Tax Technical News, No. 44]

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18 March 2003 External T.I. 2003-0002915 F -

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4 July 2001 External T.I. 2001-008815 -

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Subsection 40(3.5) - Deemed identical property

See Also

10737 Newfoundland Limited v. The Queen, 2011 DTC 1255 [at 1460], 2011 TCC 346

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Cascades Inc. v. The Queen, 2008 DTC 2387, 2007 TCC 730

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Administrative Policy

14 March 2003 Internal T.I. 2003-018297 -

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Articles

Carrie Smit, "Exchangeable Shares: Not Just Rights to Foreign Shares", CCH International Tax, No. 59, August 2011, p. 1

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Paragraph 40(3.5)(c)

Cases

Canada v. Cascades Inc., 2009 DTC 6122, 2009 FCA 135

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Words and Phrases
apply

Subsection 40(3.6) - Loss on shares

Administrative Policy

12 January 2015 Internal T.I. 2014-0560421I7 - FX losses on CFA wind-up

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10 October 2014 APFF Roundtable, 2014-0538241C6 F - 75(2) and definition of "earned income" in 146(1)

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Tax Topics - Income Tax Act - Section 146 - Subsection 146(1) - Earned Income character preservation of s. 75(2) attributed income 116
Tax Topics - Income Tax Act - Section 75 - Subsection 75(2) character preservation of attributed income/basis adjustment for denied capital loss at trust level 424

15 August 2014 Internal T.I. 2014-0538591I7 - FX losses on CFA wind-up

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Tax Topics - Income Tax Act - Section 93 - Subsection 93(2.01) no reduction under s. 93(2.01)(a) if no exempt dividend 126

23 April 2012 Internal T.I. 2012-0436921I7 - Capital Losses

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16 January 2003 External T.I. 2002-015102 -

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30 March 2001 External T.I. 2000-007414 -

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13 October 2000 Internal T.I. 2000-003110 -

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Articles

Steve Suarez, Pooja Samtani, "Using Exchangeable Shares in Inbound Canadian Transactions", 2007, 48:13, Tax Notes Int'l 1281 (The authors describe an "exchangeable share" as "a share of a Canadian corporation... that, together with some ancillary rights, replicates as closely as possible the economics (and to some extent the legal rights engaged by holders) of a share of another corporation.")

Kevin Wark, "Corporate-Owned Insurance: Revisiting Share Redemption Arrangements", CALU Report, August 2004.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 112 - Subsection 112(3.2) 0

Subsection 40(3.12) - Deemed loss for certain partners

Administrative Policy

3 July 2012 External T.I. 2012-0449701E5 - Subsection 40(3.12) and tiered ptnshps

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Subsection 40(3.15) - Excluded interest

Administrative Policy

24 June 2014 External T.I. 2014-0524331E5 - definition of excluded interest

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Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.16) distribution not a qualifying use 121

22 May 1998 T.I. 980657

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Subsection 40(3.16) - Amounts considered not to be substantial

Administrative Policy

24 June 2014 External T.I. 2014-0524331E5 - definition of excluded interest

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Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.15) 40% indebtedness increase to below original amount was "substantial" 84

Subsection 40(3.61) - Exception — estate loss carried back

Administrative Policy

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

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Subsection 40(4) - Disposal of principal residence to spouse or trust for spouse

Administrative Policy

5 November 2014 External T.I. 2014-0521891E5 F - Résidence principale et copropriété

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Tax Topics - General Concepts - Ownership whether a tacit co-ownership agreement is respected is a private law issue 118

1 September 1995 T.I. 950769 (C.T.O. "Principal Residence Provisions")

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14 July 1994 T.I. 940502 (C.T.O. "Gain on Property Transferred from Spouse")

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23 June 1992 T.I. 920894 (December 1992 Access Letter, p. 13, ¶C38-248)

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7 March 1992 T.I. (Tax Window, No. 17, p. 7, ¶1786)

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Subsection 40(7) - Property in satisfaction of interest in trust

Administrative Policy

Subsection 40(10)

Administrative Policy

7 October 2016 APFF Roundtable Q. 17, 2016-0652781C6 F - Functional currency and acquisition of control

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Tax Topics - Income Tax Act - Section 111 - Subsection 111(4) - Paragraph 111(4)(e) FX gains or losses on pre-transition debts not affected 223
Tax Topics - Income Tax Act - Section 261 - Subsection 261(9) - Paragraph 261(9)(a) exclusion of pre-transition debts from s. 111(4) 96

Subsection 40(11)

Articles

Carrie Smit, "Foreign Currency Debts and Acquisitions of Control: Beware the Unexpected Gain", International Tax (Wolters Kluwer CCH), February 2017, No. 9, p. 6

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 111 - Subsection 111(12) 495

Subsection 40(12) - Donated flow-through shares

Administrative Policy

16 October 2012 External T.I. 2012-0437911E5 - Donation of flow-through shares

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 38.1 139

14 May 2012 Internal T.I. 2011-042631E5 -

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 38.1 108