Subsection 143.3(2) - Options — limitation
Articles
Chris Falk, Stefanie Morand, Brian O'Neill, "Is there Always Certainty Regarding Tax Basis? – Limitations on Expenditures Pursuant to Sections 143.3 and 143.4", 2014 Conference Report, (Canadian Tax Foundation),14:1-36
Denial of cost of property acquired with options (p. 14:7)
[O]ne of the effects of section 143.3 is that the issuer will not have any cost for...
Subsection 143.3(3) - Corporate shares — limitation
Administrative Policy
2017 Ruling 2017-0699201R3 - Cross-border Butterfly
CRA ruled on a cross-border butterfly which entailed assets of the “Transferred Business” being transferred indirectly to a wholly-owned...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Distribution | cross-border butterfly with 4-party exchange and preceding distribution of DC to foreign parent to qualify as permitted exchange/rental property valued at nil/post-butterfly equaling cash payment | 1140 |
| Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Permitted Exchange - Paragraph (b) | cross-border butterfly including preliminary transfer of DC to foreing parent to come within “permitted exchange” | 444 |
| Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base | full cost of property acquired under 4-party exchange | 222 |
| Tax Topics - Income Tax Act - Section 212.1 - Subsection 212.1(1.1) - Paragraph 212.1(1.1)(b) | application on 4-party exchange | 291 |
Paragraph 143.3(3)(a)
Administrative Policy
2009 Ruling 2008-0300102R3 - Deductibility of interest
ACO, a public corporation, issues Notes the interest on which may at ACO's option be satisfied by issuing preferred shares with an aggregate...
25 June 2002 Internal T.I. 2002-0130177 F - DEBENTURE CONVERTIBLE
The issuer unsuccessfully sought to take an s. 20(1)(f) deduction regarding the excess of the market value of the shares into which its...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(f) | amount paid by corporation on conversion of convertible debentures was the stated capital of the issued shares, being the debentures’ face amount, so that no s. 20(1)(f) deduction | 88 |
| Tax Topics - General Concepts - Payment & Receipt | Teleglobe applied to find that amount paid by corporation on conversion of convertible debentures was the shares’ stated capital | 53 |
Articles
Chris Falk, Stefanie Morand, Brian O'Neill, "Is there Always Certainty Regarding Tax Basis? – Limitations on Expenditures Pursuant to Sections 143.3 and 143.4", 2014 Conference Report, (Canadian Tax Foundation),14:1-36
Whether share issuance for debt cancellation entails ‘property transferred…to" the corporation (p. 9)
In the context of subsections 143.3(3)...
Subparagraph 143.3(3)(a)(ii)
Administrative Policy
24 April 2001 Internal T.I. 2000-0037677 F - DEBENTURES CONVERTIBLES
Before finding that, on a (pre-s. 143.3) conversion of convertible debentures through the issuance of shares with a lower stated capital than...
Paragraph 143.3(3)(b)
Administrative Policy
29 November 2016 CTF Roundtable Q. 3, 2016-0670201C6 - Agnico-Eagle Mines Decision
CRA rejected the suggestion that Agnico-Eagle could support the realization of a capital loss under s. 39(2) when a U.S.-dollar denominated...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 39 - Subsection 39(2) | Agnico-Eagle analysis rejected | 139 |
15 April 2009 Internal T.I. 2008-0301171I7 F - 7(3)b) vs 143.3(3)
Pubco (a Canadian public corporation) issues stock options (the “Options”) to certain employees with an exercise price not less than the FMV...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(3) - Paragraph 7(3)(b) | recognition of compensation expense under GAAP on granting and then exercise of conventional Pubco options precluded by s. 7(3)(b) and notwithstanding Alcatel | 160 |
Subsection 143.3(5) - Clarification
Paragraph 143.3(5)(b)
Articles
Chris Falk, Stefanie Morand, Brian O'Neill, "Is there Always Certainty Regarding Tax Basis? – Limitations on Expenditures Pursuant to Sections 143.3 and 143.4", 2014 Conference Report, (Canadian Tax Foundation),14:1-36
Excess is of cost over FMV (p. 6)
Implicit in the [Finance] technical note statements is the assumption that, for purposes of paragraph...