Section 51

Subsection 51(1) - Convertible property

Administrative Policy

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

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Tax Topics - Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(g) - Subparagraph 40(2)(g)(ii) non-interest-bearing loan to wholly-owned ULC 163
Tax Topics - Income Tax Act - Section 51 - Subsection 51(1) s. 51 applies where issuer had a cash redemption override 200

7 October 2011 Roundtable, 2011-0412191C6 - Sec. 86 - Reorganisation of the Capital of a Corp.

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Tax Topics - Income Tax Act - Section 86 - Subsection 86(1) conversion without change to authorized capital 39

8 October 2010 Roundtable, 2010-0373231C6 F - Application of subsections 51(1) and 85(1)

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Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) share consideration need not be immediately issuable 103

2006 Ruling 2006-0177541R3 -

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29 March 2001 External T.I. 2000-005026 -

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9 September 1997 T.I. 9721405 [conversion conditional on issuer notice]

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1 November 1994 T.I. 9416305 [s. 51 applies on transfer of existing shares to corporation]

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Handbook on Securities Transactions, 94-110 (e), p. 12

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92 C.R. - Q.4

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(3) 33

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

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(g) - Subparagraph 40(2)(g)(ii) non-interest-bearing loan to wholly-owned ULC 163
Tax Topics - Income Tax Act - Section 51 - Subsection 51(1) conversion not under Note terms 175

87 C.R. - Q.67

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Tax Topics - Income Tax Act - Section 86 - Subsection 86(1) 24

IT-115R "Fractional Interests in Shares"

Articles

Didier Fr├ęchette, Ryan Rabinovitch, "Current Issues Involving Foreign Exchange", 2015 CTF Annual Conference paper

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Gabrielle M.R. Richards, "Capital Financing by Non-Residents: Section 116 Obligations", Corporate Structures and Groups, Vol. VII, No. 3, 2002, p. 375

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 116 - Subsection 116(5) 36

Hugh Chasmar, "Mutual Fund 'Switch Funds'", Taxation of Corporate Reorganizations, Canadian Tax Journal, Vol. 46, No. 1, 1998, p. 172.

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Ewens, "Convertible Property: Section 51 - Part 1", 1994 Canadian Tax Journal, Vol. 42, No. 5,.

Ross, "Equity Preferred Shares", 1992 Canadian Tax Journal, No. 3, p. 793.

Ruby, "Recent Financing Techniques", 1989 Conference Report, C.27 under "Adjustable Rate Convertible Debentures"

Subsection 51(2) - Idem [Convertible property]

Administrative Policy

1996 Corporate Management Tax Conference Round Table, Q. 13 (C.T.O. "Benefit of Conversion")

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Tax Topics - Income Tax Act - Section 86 - Subsection 86(2) 64