Section 86.1

Subsection 86.1(2) - Eligible distribution

Cases

Morasse v. The Queen, 2004 DTC 2435, 2004 TCC 239 (Informal Procedure)

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Administrative Policy

25 November 2021 CTF Roundtable, Q.3

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14 January 2020 Internal T.I. 2018-0785991I7 F - Subsection 86.1(2)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Common Share tracking shares were common shares 114

2014 Ruling 2014-0530961R3 - Cross-Border Butterfly

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Distribution U.S./Cda b/f including conversion of Foreign Spinco and TC from fiscally disregarded to regarded for Code purposes/2-stage transfer to TC of cash assets/post-b/f dividend by DC/s. 86.1 treatment/proportionate allocation of Foreign Spinco debt 1479
Tax Topics - Income Tax Act - Section 55 - Subsection 55(3.1) - Paragraph 55(3.1)(b) - Subparagraph 55(3.1)(b)(i) pro rata allocation of Foreign Spinco debt 180

10 October 2014 APFF Roundtable Q. 4, 2014-0534831C6 F - 2014 APFF Roundtable, Q. 4 - Late-filed 86.1 election & 220(3.5) penalty

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Eligible spin-offs

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 86.1 - Subsection 86.1(2) 118

Eligible spin-offs

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Tax Topics - Income Tax Act - Section 86.1 - Subsection 86.1(2) 115

Paragraph 86.1(2)(f)

Administrative Policy

7 October 2020 APFF Financial Strategies and Instruments Roundtable Q. 3, 2020-0848761C6 F - Réorganisations de sociétés étrangères avec dérivation admissibles

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 220 - Subsection 220(3.1) CRA may consider the delays until its approval of a s. 86.1 spin-off re s. 220(3.5) penalties 162