Regulation 5905 - Special Rules

Subsection 5905(1)

Articles

Penny Woolford, Francis Favre, "The Latest Foreign Affiliate Proposals: Selected Aspects", 2010 Canadian Tax Journal, No. 4, at f.n. 84:

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Subsection 5905(5.2)

Articles

Kevin Yip, "Recent Legislation Affecting Partnerships and Foreign Affiliates – Subsection 88(1) and Section 100", Canadian Tax Journal, (2013) 61:1, 229-256, at 237

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Geoffrey Turner, "The Acquisition of Control Surplus/ACB Trade-Off in the August 27, 2010 Foreign Affiliate Proposals", CCH International Tax, Nos. 54-55, December, 2010, p. 1.

Subsection 5905(5.4)

Administrative Policy

2017 Ruling 2016-0643931R3 - PUC reinstatement on emigration

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 219.1 - Subsection 219.1(4) post-acquisition sandwich structure exited through using the s. 88(1)(d) bump in combination with a continuance outside Canada 348
Tax Topics - Income Tax Act - Section 87 - Subsection 87(1) bottom corporation in a vertical amalgamation was specified to be the survivor in order to avoid a disposition under the local tax laws re its subsidiary 122

Articles

Subsection 5905(7)

Articles

Kevin Yip, "Recent Legislation Affecting Partnerships and Foreign Affiliates – Subsection 88(1) and Section 100", Canadian Tax Journal, (2013) 61:1, 229-256, at 241-242

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Subsection 5905(7.1)

Articles

Penny Woolford, Francis Favre, "The Latest Foreign Affiliate Proposals: Selected Aspects", 2010 Canadian Tax Journal, No. 4, at f.n. 32:

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Subsection 5905(7.2)

Administrative Policy

28 May 2015 IFA Roundtable Q. 7, 2015-0581611C6 - IFA 2015 Q7: Foreign affiliates-surplus adjustments

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Articles

Eric Lockwood, Maria Lopes, "Subsection 88(3): Deferring Gains on Liquidation and Dissolution", Canadian Tax Journal (2013) 61:1, 209-28, p. 209

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Subsection 5905(7.6)

Articles

Geoffrey S. Turner, "New Foreign Affiliate Capital Distribution Elections: QROCs and Reg. 5901(2)(b) Dividends", CCH International Tax, No. 67, 2012, p. 1, at p. 4

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