Paragraph (a)
Administrative Policy
30 October 2024 Internal T.I. 2023-0996541I7 - Capital gain or loss in Mt. Gox insolvency
Following the 2014 insolvency of a Japanese bitcoin platform operator (“Mt. Gox”), which had permanently lost 650,000 bitcoin, the Tokyo court...
Paragraph (d)
Administrative Policy
1994 A.P.F.F. Round Table, Q. 5
When a property is transferred with a view to securing repayment of a debt or a loan (in this case, a loan from a related company), there is no...
Paragraph (e)
See Also
Manrell v. The Queen, 2002 DTC 1222 (TCC), rev'd 2003 DTC 5225, 2003 FCA 128
The taxpayer and corporations controlled by him disposed of shares of three corporations engaged in manufacturing plastic moulds and caps and...
Anderson Estate v. The Queen, 95 DTC 758 (TCC)
The sister-in-law of the deceased who had lived with him for more than 50 years and worked on his farm venture jointly with him for most of that...
Administrative Policy
22 December 1997 External T.I. 9719575 - CONVERTING OWNERSHIP TYPE - WHETHER A DISPOSITION
The conversion of ownership of personal use real estate from a joint tenancy to a tenancy in common would not constitute a disposition or a...
29 November 1996 External T.I. 9632045 - VOTING TRUST, IS DISPOSITION RECOGNIZED ON TRANSFER
Income Tax Technical News, No. 7 gives a general indication of their criteria that are considered by RC in determining whether a transfer of...
Income Tax Technical News, No. 7, 21 February 1996 (cancelled)
"A revocable living trust should be recognized for income tax purposes at the time that legal title to property is transferred to it and ... the...
28 October 1994 External T.I. 9418635 - TRANSFER PROPERTY TO A BARE TRUST
Where legal title to a property is transferred to a bare trust without a corresponding transfer of beneficial ownership, there is no disposition...
5 August 1994 External T.I. 9412855 - HEALTH AND WELFARE TRUST AND VARIANCES TO A TRUST
The transfer of property from one health and welfare trust into a new health and welfare trust will not result in a disposition where the new...