Articles
Lanthier, "Corporate Immigration, Emigration, and Continuance", 1993 Corporate Management Tax Conference Report, c. 4.
Talakshi, "Corporate Migration", 1991 Canadian Petroleum Tax Journal, Spring 1991, p. 53.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 250 - Subsection 250(4) | 0 | |
| Tax Topics - Income Tax Act - Section 48 - Subsection 48(5) | 0 | |
| Tax Topics - Income Tax Act - Section 88.1 | 0 |
Boultbee, "Change of Residence and Continuance", 1984 Canadian Tax Journal, p. 792.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 88.1 | 0 |
Subsection 219.1(1)
Articles
Jim Samuel, Byron Beswick, "Selected Issues in Transactions Involving Debt", 2019 Conference Report (Canadian Tax Foundation), 18:1 – 27
Textual interpretation suggests that the “amount” of debt for s. 219.1 purposes is its FMV (p. 18:20)
Pursuant to subsection 219.1(1), a...
Subsection 219.1(3)
Paragraph 219.1(3)(c)
Articles
Joint Committee, "Technical Amendments Package of September 16, 2016", Submission letter of 15 November 2016
Tainting effect of minor previous reinstatements
The condition in s. 219.1(3)(c) is too restrictive because any amount of previous reinstatement...
Subsection 219.1(4)
Administrative Policy
2017 Ruling 2016-0643931R3 - PUC reinstatement on emigration
A non-resident partnership (Partnership 1) and its non-resident co-investors wished to acquire a Canadian public-company target (Target), whose...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 5905 - Subsection 5905(5.4) | bump of non-resident subsidiaries reduced by applicable surplus balances | 635 |
| 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 | 126 |