Words and Phrases - "reorganization"
Foix v. The Queen, 2021 TCC 52, aff'd 2023 FCA 38
s. 84(2) applied to a hybrid sale transaction resulting in shareholders receiving corporation's asset sales proceeds as capital dividends and sales proceeds of bumped shares
The shareholders of a private Canadian company (“W4N”) exploiting a valuable item of software had agreed in principle to sell W4N to a U.S....
Words and Phrases
reorganizationChristian Desjardins, Nik Diksic, "Cross-Border Butterflies in the Context of Public Spin-Off Transactions", 2015 CTF Annual Conference paper
History of s. 55(3.1)(b) (pp. 29:3)
[The main purpose of the original version of subsection 55(3.1) was to prevent…using the butterfly exemption...
Words and Phrases
reorganizationLocations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Distribution | 1300 |
1996 Corporate Management Tax Conference Roundtable, Q. 16 (Canadian Tax Foundation), at 24:19
narrow scope of "reorganization"
When does a reorganization end (that is, when are subsequent transactions considered part of the "reorganization" and when are they outside the...
Words and Phrases
reorganization13 January 1993 External T.I. 5-923395
RC does not as a general rule express an opinion on the reasonableness of a method proposed to be used in arriving at the fair market value of a...
Words and Phrases
reorganizationLocations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1.5) | 87 |
Kennedy v. MNR, 72 DTC 6357, [1972] CTC 429 (FCTD), aff'd 73 DTC 5359 (FCA)
sale-leaseback of principal asset did not change the manner and form in which business carried on: no reorganization
A corporation of which the taxpayer was the sole shareholder purchased a property for use as the new site for its car dealership business, paid...
Words and Phrases
reorganization