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

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 1382
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 172

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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CRA Notice

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