Administrative Policy
2022 Ruling 2022-0930901R3 F - Changes to an existing monetization arrangement
A monetization arrangement that was grandfathered from application of the synthetic disposition rules for deferring gain on the shareholding of a...
Subsection 80.6(1)
Administrative Policy
2021 Ruling 2021-0880641R3 F - Changes to existing monetization arrangements
A monetization arrangement that was grandfathered from application of the synthetic disposition rules for deferring gain on the shareholding of a...
Subsection 80.6(2)
Paragraph 80.6(2)(c)
Articles
Edward Miller, Matias Milet, "Derivative Forward Agreements and Synthetic Disposition Arrangements", 2013 Conference Report, (Canadian Tax Foundation), pp 10:1-50
Legal form prevails for leases (p. 28)
[P]ursuant to paragraph 80.6(2)(c), subsection 80.6(1) will not apply if the SDA in question is a lease of...
Paragraph 80.6(2)(e)
Articles
Edward Miller, Matias Milet, "Derivative Forward Agreements and Synthetic Disposition Arrangements", 2013 Conference Report, (Canadian Tax Foundation), pp 10:1-50
Example of over-one year SDA with disposition within one year (p. 10:38)
[W]here an "American-style" option (an option that can be exercised at...