Subsection 66.7(2) - Successor of foreign exploration and development expenses
Subsection 66.7(3) - Successor of Canadian exploration expense
Administrative Policy
11 August 2020 Internal T.I. 2018-0782181I7 - Successored CCEE and Non-Capital Losses
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Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 3 - Paragraph 3(c) | s. 3(c) deduction (e.g., under s. 67.3) cannot generate a non-capital loss | 92 |
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense | successored resource expenses are not deductible under s. 9 | 165 |
94 C.P.T.J. - Q. 11
Articles
Carr, "The Successor Corporation Rules after Bill C-18", 1992 Canadian Tax Journal, No. 6, p. 1261.
Subsection 66.7(5) - Successor of Canadian oil and gas property expense
Administrative Policy
10 October 2006 Internal T.I. 2006-0169051I7 - Successor Pool Issues
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Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - 101-110 - Section 103 - Subsection 103(1) | 45 |
Subsection 66.7(7) - Application of s. 29(25) of ITAR and ss. (1), (3), (4) and (5)
Administrative Policy
S4-F7-C1 - Amalgamations of Canadian Corporations
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12 June 1992 Memorandum (Tax Window, No. 21, p. 9, ¶2019)
Subsection 66.7(10) - Change of control
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
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Paragraph 66.7(10)(j)
Cases
Devon Canada Corporation v. The Queen, 2013 TCC 415
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Words and Phrases
reasonably attributableLocations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - 101-110 - Section 102 - Subsection 102(2) | source preservation in 2-tier partnership | 84 |
Administrative Policy
Articles
Marshall Haughey, "Tiered Partnerships: Successor Rules", Canadian Tax Highlights, Vol. 22, No. 2, February 2014, p. 13.
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Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 66.7 - Subsection 66.7(16) | 227 |
Subsection 66.7(16) - Non-successor acquisitions
Articles
Brian R. Carr, "Devon Canada Corporation v. The Queen", Resource Sector Taxation (Federated Press), Vol. IX, No. 4, 2014, p. 677.
Marshall Haughey, "Tiered Partnerships: Successor Rules", Canadian Tax Highlights, Vol. 22, No. 2, February 2014, p. 13.
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Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 66.7 - Subsection 66.7(10) - Paragraph 66.7(10)(j) | 107 |