Subsection 48.1(1) - Gain when small business corporation becomes public
Administrative Policy
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...
| Locations of other summaries | Wordcount | |
|---|---|---|
| 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...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 120.4 - Subsection 120.4(1) - Split Income - Paragraph (e) | 163 |