Section 69

Subsection 69(1) - Inadequate considerations

Paragraph 69(1)(a)

Cases

Tusk Exploration Ltd. v. Canada, 2018 FCA 121

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Tax Topics - Income Tax Act - Section 211.91 - Subsection 211.91(1) Part XII.6 tax was payable on CEE purportedly renounced on a look-back basis to NAL shareholders 497
Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) potential for double taxation under the ITA of NAL transactions 295
Tax Topics - Income Tax Act - Section 66 - Subsection 66(12.6) only a PBC can renounce 53

Survivance v. Canada, 2007 DTC 5096, 2006 FCA 129

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Deptuck v. Canada, 2003 DTC 5273, 2003 FCA 177

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Chutka v. Canada, 2001 DTC 5093 (FCA)

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Ottawa Valley Power Co. v. MNR, 69 DTC 5166, [1969] CTC 242 (Ex Ct), aff'd 70 DTC 6223, [1970] CTC 305, [1970] S.C.R. 941

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Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.1) 133

See Also

The Queen v. Yelle, 2010 DTC 5128 [at 7083], 2010 ABPC 94

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Heron Bay Investments Ltd. v. The Queen, 2009 DTC 1606, 2009 DTC 1288

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Westward Explorations Ltd. v. The Queen, 2006 DTC 2443, 2006 TCC 105

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Tax Topics - General Concepts - Fair Market Value - Other 76

CIT Financial Ltd. v. The Queen, 2003 DTC 1138, 2003 TCC 544

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Marcantonio v. MNR, 91 DTC 917 (TCC)

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) 77

Administrative Policy

28 July 2014 External T.I. 2014-0532651E5 - Loan to charitable foundation

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Tax Topics - Income Tax Regulations - Regulation 7000 - Subsection 7000(2) - Paragraph 7000(2)(a) non-interest bearing and non-arm's length term loan could trigger PDO rules 156

8 January 2002 Internal T.I. 2001-009735 -

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10 January 1992 CGA Roundtable, Q. 19, 7-912224

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8 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 10, ¶1046)

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87 C.R. - Q.68 (p. 47:38)

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Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(c) cost denied by 69(1)(a) treated as contribution of capital 134

81 C.R. - Q.3

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) 20

IT-405 "Inadequate Considerations and Dispositions"

Paragraph 69(1)(b)

Cases

Bouchard v. The Queen, 83 DTC 5193, [1983] CTC 173 (FCTD)

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See Also

DMWSHNZ Ltd. v. Commissioners for Her Majesty's Revenue and Customs, [2015] BTC 32, [2015] EWCA Civ 1036

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Tax Topics - Statutory Interpretation - Purpose purposive approach entails checking whether overall effect of transaction answers the statutory description 130

Shepp v. The Queen, 99 DTC 510 (TCC)

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Tax Topics - General Concepts - Fair Market Value - Shares 101

Gee-Gee Investments Ltd. v. MNR, 94 DTC 1419 (TCC)

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Berry v. Warnett, [1980] T.R. 299 (C.A.), rev'd [1980] BTC 239 (HL)

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Words and Phrases
gift

The Queen v. Littler, 78 DTC 6179, [1978] CTC 235 (FCA)

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Administrative Policy

7 October 2016 APFF Roundtable Q. 19, 2016-0655841C6 F - Reimbursement of attributed income

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Tax Topics - Income Tax Act - 101-110 - Section 103 - Subsection 103(1) no obligation to repay income reallocated to other partner 158
Tax Topics - Income Tax Act - Section 74.1 - Subsection 74.1(1) no domestic secondary adjustment doctrine 200

3 March 2015 External T.I. 2014-0519981E5 F - Donation avec charge / Gift with a charge

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property real estate property is one property 63

25 October 2013 External T.I. 2013-0484321E5 F - Donation entre vifs / inter vivos gift 

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6 August 2013 External T.I. 2012-0469481E5 F - Benefit under trust

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Tax Topics - Income Tax Act - 101-110 - Section 105 - Subsection 105(1) taxable benefit on sale to beneficiary at undervalue was not eliminated under s. 105(1)(a) when beneficiary sold the property 128
Tax Topics - Income Tax Act - Section 52 - Subsection 52(1) benefit on estate sale to beneficiary at under-value added to property's ACB 129

23 April 2013 Internal T.I. 2012-0466081I7 F - Usufruct created under French legislation

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Tax Topics - Income Tax Act - Section 43.1 gift of immovable subject to reservation of a usufruct gave rise to a disposition under s. 43.1 266
Tax Topics - General Concepts - Foreign Law 2-step approach to characterizing a French civil law transaction 228

12 August 2010 External T.I. 2010-0370991E5 - Debt forgiveness

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20 November 2008 Internal T.I. 2008-0281411I7 - Addition of Beneficiaries

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition addition of unrelated beneficiaries 282

31 May 2012 External T.I. 2011-0426091E5 - 98(5) - ptnsp's leasehold int if ptnr is lessor

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31 December 2004 Internal T.I. 2004-0091781I7 -

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Tax Topics - Income Tax Act - Section 84 - Subsection 84(3) 92

2004 APFF Roundtable Q. 15, 2004-0086821C6 -

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14 September 2004 External T.I. 2004-008220 -

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2001 Ruling 2001-007094 -

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2000 Ruling 2000-002395 -

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Tax Topics - Income Tax Act - Section 87 - Subsection 87(8.1) 69

17 April 2000 T.I. 1999 - 000928

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14 January 1999 External T.I. 5-982855 -

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) 52

6 November 1997 External T.I. 5-972875 -

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14 November 1996 T.I. 9635535

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12 April 1994 T.I. 940231 (C.T.O. "Intellectual Property")

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93 C.R. - Q. 39

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Revenue Canada Round Table TEI Conference, 7 December 1993, Q. 9 (C.T.O. "Non-Arm's-Length Purchase and Sale Arrangement")

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7 December 1993 Revenue Canada Round Table TEI Roundtable Q. 10, 5-933368 -

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26 January 1993 T.I. 923284 (November 1993 Access Letter, p. 512, ¶C245-051; Tax Window, No. 28, p. 1, ¶2383)

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92 C.R. - Q.21

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17 February 1992 T.I. (Tax Window, No. 16, p. 21, ¶1752)

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30 November 1991 Round Table (4M0462), Q. 3.3 - Issuing of Shares: Consideration Less than the F.M.V. (C.T.O. September 1994)

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18 December 1989 T.I. (May 1990 Access Letter, ¶1219)

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86 C.R. - Q.23

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85 C.R. - Q.9

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Articles

Marie Emmanuelle Vaillancourt, Alan Shragie, "Non-Arm's Length Stock Options Transfers", CCH Tax Topics, No. 1985, 25 March 2010, p. 1.

Innes, "If the Tax Treatment of Accrued Gains on Inventory at Death", Estates and Trust Journal, Vol. 12, 1992, p. 122.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 70 - Subsection 70(2) 0

Subparagraph 69(1)(b)(i)

See Also

Mady v. The Queen, 2017 TCC 112

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Tax Topics - Income Tax Act - Section 74.5 - Subsection 74.5(11) transfer from wife to higher-income husband was infused with his income-splitting purpose (as well as regulatory breach if she didn’t transfer) 355
Tax Topics - General Concepts - Ownership wife and children did not acquire beneficial interest in shares the taxpayer was to transfer to them, under tax plan, until the share transfer occurred 253
Tax Topics - Income Tax Act - Section 86 - Subsection 86(2) family members did not acquire beneficial interest in new shares until after completion of s. 86 reorg 285
Tax Topics - General Concepts - Fair Market Value - Shares arm’s length sales price established FMV for closing-date internal transfer of same shares 470
Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) was not responsible under s. 163(2) for the unbeknownst sharp practice of his tax advisor 658
Tax Topics - General Concepts - Price Adjustment Clause no jurisdiction to comment on application of price adjustment clause where the affected taxpayers are not appellants 223

Paragraph 69(1)(c)

Cases

Cassan v. The Queen, 2017 TCC 174

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Words and Phrases
gift
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Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts common law gift was vitiated by loan to donor at unreasonably low rate 746
Tax Topics - Income Tax Act - Section 143.2 - Subsection 143.2(12) although borrowing by taxpayers had a term of 9.3 years, they had a reasonable expectation of refinancing with the promoter’s assistance 466
Tax Topics - Income Tax Act - Section 143.2 - Subsection 143.2(7) - Paragraph 143.2(7)(a) loans were not bona fide in that not handled with commerciality 655
Tax Topics - Income Tax Regulations - Regulation 7000 - Subsection 7000(2) - Paragraph 7000(2)(d) no requirement to accrue interest on index-linked note in a year when the return thereon was not determinable 577
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) interest on loan to acquire LP units was deductible as there was a prospect of gross income being allocated by LP in 19 years’ time 583
Tax Topics - Statutory Interpretation - Realization Principle amount should not be recognized until ascertainable 67

Gervais v. The Queen, 85 DTC 5004, [1984] CTC 661 (FCTD)

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Tax Topics - Statutory Interpretation - Provincial Law 52

Hutterian Brethren Church of Wilson v. The Queen, 79 DTC 5474, [1980] CTC 1 (FCA)

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Administrative Policy

22 March 2016 Internal T.I. 2013-0506561I7 - Property acquired on a return of capital

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Tax Topics - Income Tax Act - Section 69 - Subsection 69(4) FMV cost of property acquired on QROC distribution 115
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base FMV cost of contributed or distributed property 51
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure QROC distribution by a foreign affiliate to its Canadian shareholder of ECP results in ECE to the shareholder of the property’s FMV 210
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Cumulative Eligible Capital - Element A.1 no gain to FA transferor of ECP 93

10 October 2014 APFF Roundtable, 2014-0538621C6 F - Disposition en contrepartie de 1$

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26 June 2013 External T.I. 2013-0490711E5 F - Disposition en contrepartie de 1$

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Words and Phrases
gift

21 December 2012 Internal T.I. 2009-0327221I7 - Paragraph 7(1)(e) - Death of a Taxpayer

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Income Tax Technical News No. 44 13 April 2011 [archived]

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Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a) inter-provincial loss shifting 65
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) exchangeable debenture appreciation not recognized 90
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(f) exchangeable debenture appreciation not recognized 106
Tax Topics - Income Tax Act - Section 49 - Subsection 49(1) exchangeable debenture exercise 84
Tax Topics - Treaties - Income Tax Conventions - Article 10 use of s.à r.l. 123

IT-464R, para. 8

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22 May 1997 External T.I. 5-964143 -

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22 January 1996 T.I. 953006 (C.T.O. "Gift or Sale?")

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May 1995 Executive Institute Round Table, Q. 24 (C.T.O. "Employee Stock Option")

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October 1992 Central Region Rulings Directorate Seminar, Q. B. (May 1993 Access Letter, p. 229)

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September 1992 B.C. Revenue Canada Round Table, p. 21 (May 1993 Access Letter, p. 227)

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Articles

Atlas, "Tax Planning for Foreign Inheritances", Tax Topics, No. 1247, 1 February 1996

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Subsection 69(2)

Cases

Indalex Ltd. v. The Queen, 86 DTC 6039, [1986] 1 CTC 219 (FCTD), aff'd 88 DTC 6053, [1988] 1 CTC 60 (FCA)

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Administrative Policy

93 C.R. - Q. 33

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93 C.M.TC - Q. 17

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93 C.M.TC - Q. 13

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89 C.R. - Calderwood Paper (C.42)

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IC 94-4 "International Transfer Pricing: Advance Pricing Agreements (APA)"

IC 87-2 "International Transfer Pricing and Other International Transactions"

IT-468R "Management or Administration Fees Paid to Non-Residents"

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Articles

Purdy, Zanchelli, "Calculating and Supporting Management Fees (A Departure from the 'Back of the Envelope' Approach)", International Tax Planning, 1996 Canadian Tax Journal, Vol. 44, No. 1, 1996, p. 157.

Boidman, Lawlor, "Transfer Pricing in the Absence of Comparable Market Prices: Canada", Studies on International Fiscal Law, Volume LXXIIa, p. 323 (International Fiscal Association, Rotterdam, 1992).

Finance

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Subsection 69(3)

Cases

R. v. Kleysen, 96 DTC 6265 (Man QB)

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Administrative Policy

18 March 1992 T.I. (Tax Window, No. 18, p. 4, ¶1816)

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) 68

91 C.R. - Q.30

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) 24

Articles

Yukich, "Taxation of Export Sales from Canada", 1993 Corporate Management Tax Conference Report, c. 9.

Subsection 69(4) - Shareholder appropriations

Cases

Boardman v. The Queen, 85 DTC 5628, [1986] 1 CTC 103 (FCTD)

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See Also

Husky Oil Limited v. Canada, 2010 DTC 5089 [at 6887], 2010 FCA 125

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Javalin Founderies & Machine Works Ltd. v. MNR, 67 DTC 392 (TAB)

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Administrative Policy

31 May 2017 External T.I. 2016-0642621E5 - Donation to private foundation

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Tax Topics - Income Tax Act - Section 38 - Paragraph 38(a.1) s. 38(a.1) prevails over s. 69(4) 181

22 March 2016 Internal T.I. 2013-0506561I7 - Property acquired on a return of capital

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Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(c) FMV cost of property acquired on contribution of capital 115
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base FMV cost of contributed or distributed property 51
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure QROC distribution by a foreign affiliate to its Canadian shareholder of ECP results in ECE to the shareholder of the property’s FMV 210
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Cumulative Eligible Capital - Element A.1 no gain to FA transferor of ECP 93

15 November 2013 Internal T.I. 2013-0478621I7 F - Transfer of intangibles - TP adjustments

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Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) group sale with Canco not charging for intangibles should engage s. 247(2) 141
Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) secondary adjustment re group sale with Canco not charging for intangibles 240

Subsection 69(5) - Idem [Shareholder appropriations]

Administrative Policy

14 May 2015 CLHIA Roundtable, 2015-0573841C6 - 2015 CLHIA Roundtable – Winding-up and ACB

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Tax Topics - Income Tax Act - Section 148 - Subsection 148(7) s. 69(5) generally prevails over s. 148(7) 106

Subsection 69(11) - Deemed proceeds of disposition

Cases

Canada v. Oxford Properties Group Inc., 2018 FCA 30

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Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) using the s. 88(1)(d) bump on newly-formed rental property LPs to avoid indirect recapture income under s. 100(1) was abusive 885
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(d) s. 88(1)(d) bump is intended to permit the transfer of ACB that otherwise would be lost to another property that is taxed in the same way 349
Tax Topics - Income Tax Act - Section 98 - Subsection 98(3) - Paragraph 98(3)(c) s. 98(3)(c) bump is intended to avoid gain realization where there has been no economic gain 259
Tax Topics - Income Tax Act - Section 100 - Subsection 100(1) purpose is to ensure that latent recapture will be recognized on sale to tax exempt 244
Tax Topics - Income Tax Act - Section 97 - Subsection 97(2) object includes ultimate taxation of the deferred gain 224
Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) GAAR question as to determining a provision’s object was subject to correctness standard 155
Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. statement that amendment was for “clarification” was self-serving 199
Tax Topics - Statutory Interpretation - Interpretation Act - Subsection 45(2) determination of whether amendment merely clarified requires review of pre-amendment state of law 135

See Also

Oxford Properties Group Inc. v. The Queen, 2016 TCC 204, rev'd 2018 FCA 30

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Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) no abuse in using 88(1)(d) bump to avoid s. 100 after 3-year s. 69(11) period 537
Tax Topics - Income Tax Act - Section 248 - Subsection 248(10) subsequent sale part of series as it utilized the benefit of previous LP packaging transactions 371
Tax Topics - Income Tax Act - Section 97 - Subsection 97(2) purpose not to tax underlying recapture on subsequent LP unit sale 415
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(d) purpose: to push down ACB of shares of sub to qualifying non-depreciable property 474
Tax Topics - Statutory Interpretation - Interpretation Act - Subsection 45(2) subsequent amendment shed light on scope of previous version 99
Tax Topics - Income Tax Act - Section 100 - Subsection 100(1) S. 100 operates only on outside basis gain 278
Tax Topics - Income Tax Act - Section 98 - Subsection 98(3) - Paragraph 98(3)(c) purpose: to preserve high outside basis through push down 285

Administrative Policy

2 December 2014 CTF Roundtable, Q2(c)

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2014 Ruling 2014-0523221R3 - Amalgamation of mutual funds

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 111 - Subsection 111(5.5) amalgamation of two mutual fund corporations each with capital losses 127
Tax Topics - Income Tax Act - Section 256 - Subsection 256(7) - Paragraph 256(7)(b) amalgamation of two mutual fund corporations each with capital losses 126

21 October 2013 Internal T.I. 2013-0505831I7 - Rollover and subsequent disposition of property

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 85.1 - Subsection 85.1(3) s. 69(11)(b) not applied 243

2002 Ruling 2001-011607 -

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1996 Tax Executives Round Table, Q. XIL (No. 9639150)

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18 August 1995 TI 9515455

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93 CPTJ - Q.14

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) 43

91 CPTJ - Q.1

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89 C.R. - Read Paper (C.18)

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Articles

Perry Truster, "Loss Trading and Subsection 69(11)", Tax for the Owner-Manager, Vol. 17, No. 2, April 2017

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David M. Williamson, Michael H. Manly, "Subsection 69(11) - Unexpected Problems from Inappropriate Positions", Corporate Structures and Groups, Vol. V, No. 4, 1999, p. 285.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(10) 0

Marc N. Ton-That, "Unexpected Problems under Subsection 69(11)", Corporate Structures and Groups, Vol. V, No. 3, 1999, p. 268.

Subsection 69(13) - Amalgamation or merger

Administrative Policy

S4-F7-C1 - Amalgamations of Canadian Corporations

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 100 - Subsection 100(2.1) s. 100(2.1) applies to non-qualifying amalgamation 58
Tax Topics - Income Tax Act - Section 111 - Subsection 111(12) application following amalgamation 103
Tax Topics - Income Tax Act - Section 116 - Subsection 116(1) deemed tcp following amalgamation 155
Tax Topics - Income Tax Act - Section 13 - Subsection 13(5.1) continuity of s. 13(5.1) on amalgamation 126
Tax Topics - Income Tax Act - Section 165 - Subsection 165(1) Amalco can continue objection and receive refunds 145
Tax Topics - Income Tax Act - Section 169 Amalco can continue objection 97
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(n) reserve after amalgamation 50
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Shareholder shareholder need not hold shares 82
Tax Topics - Income Tax Act - Section 251 - Subsection 251(3.1) deemed non-arm's length relationship on amalgamation 164
Tax Topics - Income Tax Act - Section 256 - Subsection 256(7) - Paragraph 256(7)(b) realted party, majority and 50% group exceptions 448
Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(iii) reserve after amalgamation 50
Tax Topics - Income Tax Act - Section 66.7 - Subsection 66.7(7) successoring where non-wholly owned amalgamation 85
Tax Topics - Income Tax Act - Section 7 - Subsection 7(1.4) s. 87(5) not applicable 104
Tax Topics - Income Tax Act - Section 80.01 - Subsection 80.01(3) non-87 amalgamation/no FX gain 159
Tax Topics - Income Tax Act - Section 84 - Subsection 84(3) no deemed dividend to dissenter on amalgamation 81
Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) election filing by Amalco 103
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1.1) s. 87(1.1) qualifies for all s. 87 purposes 60
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1.2) successoring where non-wholly owned amalgamation 85
Tax Topics - Income Tax Act - Section 87 - Subsection 87(10) deemed listing of temporary Amalco shares 114
Tax Topics - Income Tax Act - Section 87 - Subsection 87(11) gain if high PUC is sub shares 47
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1) presumptive satisfaction of s. 87(1)(a)/dissent and squeeze-outs onside 260
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(a) new corp/deemed year end coinciding or not with acquisition of control 0
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(b) Amalco must follow predecessor's valuation method subject to truer picture doctrine 58
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(c) reserve after amalgamation 103
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(d) cost amount carryover 135
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(e.1) s. 100(2.1) applies to non-qualifying amalgamation 58
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(o) no continuity rule for non-security options 133
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(q) pre-amalgamation services 96
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2.11) loss-carry back to parent 159
Tax Topics - Income Tax Act - Section 87 - Subsection 87(2.1) dovetailing with s. 88(1.1) 38
Tax Topics - Income Tax Act - Section 87 - Subsection 87(3.1) 328
Tax Topics - Income Tax Act - Section 87 - Subsection 87(3) PUC shifts 181
Tax Topics - Income Tax Act - Section 87 - Subsection 87(4) fractional share cash/ACB or value shift/implied non-recognition for predecessor shares 247
Tax Topics - Income Tax Act - Section 87 - Subsection 87(7) dovetailing with s. 78 and 112(12) 171
Tax Topics - Income Tax Act - Section 87 - Subsection 87(9) allocation of s. 87(9)(c)(ii) excess as parent chooses 218
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(d) late designation 106
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1.1) dovetailing with s. 87(2.1) 56
Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) partnership dissolution on amalgamation 123
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) deemed non-arm's length relationship on amalgamation 415
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) deemed non-arm's length relationship on amalgamation 323
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(14) class continuity on non-arm's length amalgamation 311
Tax Topics - Income Tax Regulations - Regulation 8503 - Subsection 8503(3) - Paragraph 8503(3)(b) pre-amalgamation services 96

5 March 1992 External T.I. 5-913271 -

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Subsection 69(14) - New taxpayer

Administrative Policy

20 February 2003 External T.I. 2002-015667 -

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