Subsection 48.1(1) - Gain when small business corporation becomes public
Administrative Policy
4 December 2000 External T.I. 2000-0001715 F - Qualified small business corporation share
Substantially all of the assets of a private corporation (Holdco) were the shares of a connected corporation (Opco) carrying on a Canadian active...
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Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Canadian-Controlled Private Corporation - Paragraph (c) | para. (c) relevant where Holdco’s asset was shares of Opco but Opco shares also were held by Pubco | 74 |
26 September 1996 External T.I. 9627665 - ELECTION TO CRYSTALIZE GAINS ON GOING PUBLIC
S.48.1 will not be available to individuals who hold shares of a Canadian-controlled private corporation that amalgamates with a public...
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Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Public Corporation | 74 |
Articles
Martin Lee, Manu Kakkar, Thanusan Raveendran, "Section 48.1: TOSI Trap in Going Public", Tax for the Owner-Manager (Canadian Tax Foundation), Vol. 20, No. 1, January 2020, p. 4
- An election under s. 48.1(1) (where available) deems the electing shareholders to have disposed of their shares of a small business corporation...
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Tax Topics - Income Tax Act - Section 120.4 - Subsection 120.4(1) - Split Income - Paragraph (e) | 181 |