Administrative Policy
2022 Ruling 2022-0930901R3 F - Changes to an existing monetization arrangement
A monetization arrangement that was grandfathered from application of the synthetic disposition rules for deferring gain on the shareholding of a...
Subsection 80.6(1)
Administrative Policy
2021 Ruling 2021-0880641R3 F - Changes to existing monetization arrangements
A monetization arrangement that was grandfathered from application of the synthetic disposition rules for deferring gain on the shareholding of a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Transitional Provisions and Policies | agreement novation likely would lose grandfathering | 188 |
Subsection 80.6(2)
Paragraph 80.6(2)(c)
Articles
Edward Miller, Matias Milet, "Derivative Forward Agreements and Synthetic Disposition Arrangements", 2013 Conference Report, (Canadian Tax Foundation), pp 10:1-50
Legal form prevails for leases (p. 28)
[P]ursuant to paragraph 80.6(2)(c), subsection 80.6(1) will not apply if the SDA in question is a lease of...
Paragraph 80.6(2)(e)
Articles
Edward Miller, Matias Milet, "Derivative Forward Agreements and Synthetic Disposition Arrangements", 2013 Conference Report, (Canadian Tax Foundation), pp 10:1-50
Example of over-one year SDA with disposition within one year (p. 10:38)
[W]here an "American-style" option (an option that can be exercised at...