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apply

Summary Under

deeming rule in s. 40(5)(c) applies for purposes of the preconditions in s. 40(3.3) as to whether s. 40(3.4) applies

Where a public corporation ("Parentco") holding shares of a public corporation ("Subco") with an accrued loss, sells the shares to a...

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Words and Phrases

Summary Under

s. 85(2.1) does not apply where s. 84.1(1) applies even if there is no grind under the s. 84.1(1)(a) formula

Mr. A transferred his shares of Opco with an ACB and PUC of $100 and $100,000, respectively, to Holdco on a s. 85(1) rollover basis in...

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Words and Phrases

Full Title

Canada v. Cascades Inc., 2009 DTC 6122, 2009 FCA 135

Summary Under

"apply" does not mean "triggered results under"

The trial judge had found that the stop-loss rule in s. 40(3.4) did not apply to the disposition by the taxpayer of shares of a subsidiary ("PII")...

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Words and Phrases

Full Title

Collins & Aikman Products Co. v. The Queen, 2009 DTC 1179 [at at 958], 2009 TCC 299, aff'd 2010 DTC 5164 [at 7293], 2010 FCA 251

Summary Under

limited scope of PUC provisions reflected a policy choice

The taxpayer ("Products"), which was a corporation resident in the U.S., transferred the shares of its subsidiary ("CAHL"), which was non-resident...

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Words and Phrases