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Summary Under

FA sub shares acquired “on” disposition of FA parent shares occurring on completion of liquidation and dissolution process

On a liquidation and dissolution (“L&D”) of FA1, it distributed to its parent (ACo) its shares of (wholly-owned) FA2 and FA3 and other...

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Words and Phrases

Summary Under

Descarries failed to recognize breadth of s. 84(2)

What is the CRA position on Descarries? After noting that the case was not appealed because in the result it was favourable and it was only an...

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Full Title

David v. The Queen, 75 DTC 5136, [1975] CTC 197 (FCTD)

Summary Under

proceeds from the sale of cash-rich company to pension fund for wind-up 5 months later were "otherwise appropriated ... on the winding-up"

Approximately four months after the corporation of which the taxpayers (the "David group") were shareholders sold its principal business assets,...

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Words and Phrases