Subsection 66.3(1) - Exploration and development shares
Administrative Policy
89 C.P.T.J. - Q. 14
Where an amalgamated corporation on the amalgamation acquires pre-November 13, 1981 flow-through shares owned by a predecessor, those shares will...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 87 - Subsection 87(1) | 57 |
Subsection 66.3(3) - Cost of flow-through shares
See Also
JES Investments Ltd. v. The Queen, 2006 DTC 3608, 2006 TCC 508, aff'd 2007 FCA 337
A corporation with which the taxpayer had entered into a flow-through share agreement did not in fact incur CEE or renounce to the taxpayer. In...
Administrative Policy
17 September 2018 External T.I. 2018-0751571E5 F - Adjusted cost base of property
A taxpayer ("Taxpayer") subscribed for limited partnership units in a limited partnership ("LP"), which used the funds raised to subscribe for...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 85 - Subsection 85(3) - Paragraph 85(3)(f) | operation of s. 85(3)(f) on wind-up of flow-through LP not affected by s. 63.3(3) | 86 |
Articles
Gregory M. Johnson, Wesley R. Novotny, "An Update on Flow-through Shares in the Energy Sector", 2016 Conference Report (Canadian Tax Foundation),12:1-39
Application based only on valid flow-through share (FTS) agreement (p. 12:7)
... The Canada Revenue Agency's (CRA's) administrative position is...