Subsection 44.1(1) - Definitions
Eligible Small Business Corporation
Administrative Policy
3 November 2004 Internal T.I. 2004-0083791I7 F - Paragraphe 44.1(2)
After February 27, 2000, but before October 18, 2000 (i.e., before the effective date of the introduction of s. 44(10)(d)), an individual sold...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Start-Up and Liquidation Costs | business did not commence with zoning application that was not actively pursued | 120 |
| Tax Topics - Income Tax Act - Section 44.1 - Subsection 44.1(8) | pre-condition of carrying on business not satisfied / general overview provided | 328 |
Qualifying Disposition
Administrative Policy
27 November 2012 External T.I. 2012-0445941E5 F - Action déterminée de petite entreprise
In finding that shares issued from treasury of a corporation to a family trust, which later were distributed to a capital beneficiary, did not...
10 February 2012 External T.I. 2010-0385861E5 F - Actions de remplacement
Respecting the application of s. 44.1 to an initial public offering of common shares (“Subscribed Shares”) by a Canadian-controlled private...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 44.1 - Subsection 44.1(1) - Replacement Share | application to IPO of CCPC | 126 |
Replacement Share
Administrative Policy
10 February 2012 External T.I. 2010-0385861E5 F - Actions de remplacement
Respecting the application of s. 44.1 to an initial public offering of common shares (“Subscribed Shares”) by a Canadian-controlled private...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 44.1 - Subsection 44.1(1) - Qualifying Disposition | elements of qualifying disposition definition | 134 |
11 May 2010 External T.I. 2009-0339151E5 F - Paragraphe 44.1 - " actions de remplacement
Must a "replacement share" continue to be a share of an eligible small business corporation after its issue in order for the capital gain deferral...
Subsection 44.1(8)
Administrative Policy
3 November 2004 Internal T.I. 2004-0083791I7 F - Paragraphe 44.1(2)
A newly-formed corporation used its cash share subscription proceeds almost entirely to purchase a piece of land for which, to date, a required...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 44.1 - Subsection 44.1(1) - Eligible Small Business Corporation | shares were not of an eligible small business corporation given that only business activity was desultory zoning application | 193 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Start-Up and Liquidation Costs | business did not commence with zoning application that was not actively pursued | 120 |