Subsection 47(1) - Identical properties
See Also
Gervais v. The Queen, 2014 TCC 119, 2015 DTC 1026 [at at 105]
The taxpayer purchased 1.04M preferred shares from her husband on income account at a cost of $1.04M and was gifted a further 1.04M shares on a...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Shares | rollover followed by immediate resale | 359 |
Administrative Policy
7 October 2011 Roundtable, 2011-0412141C6 F - Whether shares of different classes are identical
The issued and outstanding shares of two classes of shares of a QBCA corporation have identical attributes except that the 100 Class A shares and...
8 October 2010 APFF Roundtable, 2010-0373301C6 F - Classes of shares with identical characteristics
Under s. 49 of the new Québec Business Corporations Act, it is possible to create classes and series of shares with exactly the same rights and...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Paid-Up Capital | identical but separate QBCA classes would have separate PUC | 103 |
24 May 2001 External T.I. 2001-0069045 - SHORT SALE AND IDENTICAL PROPERTIES
"... We would consider a short sale entered into in order to hedge a taxpayer's position with respect to identical shares held on capital account...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 39 - Subsection 39(4) | identical property rules apply to ACB of shares sold on both ends of a short sale on capital account | 195 |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Short Sales | 161 |
20 July 2000 External T.I. 2000-0035415 - SPECIFIC IDENTIFICATION OF SECTION 7 SHARES47(1)
Specific numerical example illustrating the identical property provisions and the specific identification position described in Income Tax...
2000 Ruling 2000-0007493 - IDENTICAL PROPERTIES
An exchangeable share and a share of the U.S. parent are not identical properties.
15 October 1997 External T.I. 9725315 - CCPC OPTIONS
Discussion of inter-relationships between ss.7(1.3) and 47(1).
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1) - Paragraph 110(1)(d) | 38 | |
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1.3) | 67 |
30 November 1996 Ruling 9717003 - GAAR, IDENTICAL PROPERTIES
In order to avoid averaging with the low ACB of shares currently held by them that are subject to an escrow agreement, employees of a public...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | 125 |
2 July 1991 T.I. (Tax Window, No. 5, p. 14, ¶1324)
Identical properties acquired after December 31, 1971 to which the attribution rules apply constitute a separate pool from other identical...
30 October 89 T.I. (March 1990 Access Letter, ¶1159)
RC is not in the practice of applying s. 47(1) in the situation where a taxpayer purchases his wife's 1/2 interest in their condominium.
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|---|---|---|
| Tax Topics - Income Tax Act - Section 74.2 - Subsection 74.2(1) | 41 |
IT-78 "Capital Property Owned on December 31, 1971 - Identical Properties"
IT-387R2 "Meaning of 'Identical Properties'"
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 54 - Superficial Loss | 27 |
Subsection 47(3)
Administrative Policy
12 September 2022 External T.I. 2021-0886441E5 - Restricted Stock Unit Plan – Adjusted Cost Base
S. 7(1.31) applies in relation to shares of a public corporation if a share of the corporation is acquired under an agreement described in s....
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1.31) | example of application of s. 7(1.31) to acquisition and immediate sale of shares pursuant to RSUs | 244 |