Section 74.4

Subsection 74.4(2) - Transfers and loans to corporations

Administrative Policy

6 October 2017 APFF Roundtable, Q.9

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Tax Topics - Income Tax Act - Section 74.5 - Subsection 74.5(5) unborn children and spouse not designated persons re freezer trust 215

May 2016 Alberta CPA Roundtable, Income Tax Q.9

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Words and Phrases
one of the main purposes

8 December 2015 External T.I. 2015-0613401E5 F - Attribution Rules

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11 December 2015 External T.I. 2015-0601561E5 F - Attribution Rules

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2 June 2015 External T.I. 2015-0570071E5 F - Attribution Rules Trust

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10 October 2014 APFF Roundtable Q. 19, 2014-0538041C6 F - 2014 APFF Roundtable, Q. 19 - Stock dividend

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1.1) not engaged if stock dividend is proportional 203
Tax Topics - Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) SI apportionment to stock dividend prefs 245
Tax Topics - Income Tax Regulations - Regulation 6205 - Subsection 6205(2) purpose test in Reg. 6205(2)(a) is not necessarily accomplished by all estate freezes/"arrangement" broad 403

1 April 2003 External T.I. 2003-0004125 F -

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5 March 2001 External T.I. 2001-006772 -

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20 March 1997 T.I. 963505

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20 March 1995 T.I. 942992 ("C.T.O. 74.2(2) and Amalgamation")

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12 October 1994 External T.I. 5-941148 -

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11 May 1994 T.I. 913071 (C.T.O. "Transfer of Property re 74.4(2) Amalgamation")

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17 February 1994 T.I. 940111 (C.T.O. "Attribution Control Co Invest in Preference Share of 2nd Co")

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26 January 1994 External T.I. 5-932995 -

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30 March 1993 T.I. (Tax Window, No. 29, p. 23, ¶2454)

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92 C.R. - Q.34

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21 August 1992 T.I. (Tax Window, No. 23, p. 24, ¶2154)

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27 June 1991 Memorandum (Tax Window, No. 4, p. 13, ¶1320)

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11 June 1991 T.I. (Tax Window, No. 4, p. 29, ¶1298)

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2 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 14, ¶1080)

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30 January 1990 Memorandum (June 1990 Access Letter, ¶1263)

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ATR-36 (4 Nov. 88)

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86 C.R. - Q.42

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Articles

Emes, "Planning for Immigration to Canada from Countries other than the United States", 1993 Corporate Management Tax Conference Report, c. 13.

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Tax Topics - Income Tax Act - Section 56 - Subsection 56(4.1) 4

Subsection 74.4(4) - Benefit not granted to a designated person

Administrative Policy

2016 Ruling 2014-0552321R3 F - Trust to trust Transfer

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition - Paragraph (f) para. (f) exception applied on transfer from old discretionary inter vivos family trust to new trust with terms considered to be substantively the same 750
Tax Topics - Income Tax Act - 101-110 - Section 108 - Subsection 108(1) - Trust - Paragraph (g) trust holding property on its 21st anniversary for minors was not subject to s. 104(4) as their shares would have been deemed under the Trust Deed to be irrevocably determined by then 397
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(5.8) 104(5.8) applied to transfer to new trust with the same beneficiaries and essentially the same terms 45

7 November 2014 External T.I. 2014-0549571E5 F - Attribution rule

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8 February 1993 T.I. (Tax Window, No. 29, p. 7, ¶2422)

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