Section 83

Subsection 83(2) - Capital dividend

Cases

2529-1915 Québec Inc. v. Canada, 2009 DTC 5023 [at 5585], 2008 FCA 398

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Sham capital dividend elections for distributions of what should have been known to be income-account gains were shams 245
Tax Topics - General Concepts - Tax Avoidance capital dividend elections for distributions of what should have been known to be income-account gains were shams 245
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business shares premiums received for marketing tax scheme were business income 196
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Shares shares acquired for immediate resale as part of capital dividend account generation scheme were on income account 160
Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business shares premiums received for marketing tax scheme were business income 204

Dale v. Canada, 97 DTC 5252 (FCA)

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Administrative Policy

4 January 2012 External T.I. 2011-0414731E5 F - Interaction between 84.1 and 83(2) ITA

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26 September 2002 T.I. 2002012895

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91 C.R. - Q.23

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29 August 1991 T.I. (Tax Window, No. 8, p. 21, ¶1423)

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25 June 1990 Memorandum (November 1990 Access Letter, ¶1523)

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Subsection 83(2.1) - Idem [Capital dividend]

Cases

Groupe Honco Inc. v. Canada, 2014 DTC 5006, 2013 FCA 128, aff'g 2013 DTC 1032 [at 149], 2012 TCC 305, infra

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Words and Phrases
one of the main purposes

See Also

Groupe Honco Inc v. The Queen, 2013 DTC 1032 [at 149], 2012 TCC 305, aff'd 2013 FCA 128, supra

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Barclays Mercantile Industrial Finance Ltd. v. Melluish, [1990] BTC 209 (Ch. D.)

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Words and Phrases
main object

Administrative Policy

2016 Ruling 2015-0624611R3 - Capital Dividend Account

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (d) proceeds of predecessor’s policy added to Amalco’s CDA when received 170

11 January 1994 T.I. 933423 (C.T.O. "CDA Anti-Avoidance Rules")

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 83 - Subsection 83(2.4) 70

Articles

Michael McGowan, "HMRC v Lloyds Bank Leasing (No 1) Ltd: the troublesome increase in the scope of the "sole or main object" test", [2015] British Tax Review, No.5 2015 (Thomson Reuters (Professional) UK Limited), p. 649

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Purpose/Intention 644

Nathan Boidman, Canadian Tax Highlights, Vol. 22, No. 5, May 2014, p. 9.

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Subsection 83(2.2)

Subsection 83(2.3)

Subsection 83(2.4) - Idem [Where s. (2.1) does not apply]

Administrative Policy

11 January 1994 T.I. 933423 (C.T.O. "CDA Anti-Avoidance Rules")

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 83 - Subsection 83(2.1) 56

Subsection 83(3)