Section 51

Subsection 51(1) - Convertible property

Administrative Policy

2020 Ruling 2019-0824211R3 F - Post-mortem Hybrid Pipeline

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Tax Topics - Income Tax Act - Section 84 - Subsection 84(2) pipeline rulings where the underlying operating business was sold for cash after the death and before the pipeline transactions 450

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 171
Tax Topics - Income Tax Act - Section 51 - Subsection 51(1) s. 51 applies where issuer had a cash redemption override 208

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 171
Tax Topics - Income Tax Act - Section 51 - Subsection 51(1) conversion not under Note terms 185

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

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Tax Topics - Income Tax Act - Section 86 - Subsection 86(1) reorganization of capital generally requires articles of amendment 216

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 123

11 January 2010 External T.I. 2009-0340591E5 F - Specified class - 256(1.1) of the Act

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Tax Topics - Income Tax Act - Section 256 - Subsection 256(1.1) - Paragraph 256(1.1)(d) s. 256(1.1)(d) must be met throughout the period the shares were outstanding – but can cleanse with s. 51 exchange 442

2006 Ruling 2006-0177541R3 - Amendments to Debt, Conversion

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29 March 2001 External T.I. 2000-0050265 - Mutual fund corporation - "switch" shares

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9 September 1997 External T.I. 9721405 - CONVERSION OF DEBT OBLIGATION

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Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Subparagraph 212(1)(b)(vii) notice by issuer before convertible 95
Tax Topics - Income Tax Act - Section 51.1 conversion subject to issuer notice 173

1 November 1994 External T.I. 9416305 - EXCHANGE SHARES OF SAME CORP

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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

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 Fréchette, 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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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