Qualifying Business Transfer

Administrative Policy

18 September 2025 CLHIA Roundtable Q. 2, 2025-1067931C6 - Deemed Value of Life Insurance and QSBC

non-application of s. 110.6(15)(a)(i) to “qualifying business transfer” definition

As the definition of qualified small business corporation share and small business corporation were not relevant to the determination of whether a disposition of a share of a subject corporation was a “qualifying business transfer” under the s. 248(1) definition for purposes of the employee ownership trust rules, the deeming rule in s. 110.6(15)(a)(i) did not apply for such purposes.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 84.1 - Subsection 84.1(2.31) - Paragraph 84.1(2.31)(b) - Subparagraph 84.1(2.31)(b)(iii) application of s. 110.6(15)(a)(i) to ss. 84.1(2.31) and (2.32) 26
Tax Topics - Income Tax Act - Section 110.63 - Subsection 110.63(1) - Qualifying Canadian Entrepreneur Incentive Property application of s. 110.6(15)(a)(i) to “qualifying Canadian entrepreneur incentive property” definition 62

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