Words and Phrases - "substituted"

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22 June 2016 Internal T.I. 2016-0632821I7 F - 93(2.01) & Capital Contribution

ordinary meaning of “substituted”

Canco contributed (for no share consideration) its shares of a non-resident Finco subsidiary (Luxco2 – which previously had paid exempt...

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Words and Phrases
substituted
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 93 - Subsection 93(2.01) a contribution of FA1 shares to FA2 causes the FA2 shares to be substituted property for s. 93(2.01) purposes 195
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(a) - Subparagraph 95(2)(a)(ii) - Clause 95(2)(a)(ii)(B) inter-affiliate loan generating deemed active business funded out of an interest-free loan from Canco 105

26 May 2016 IFA Roundtable Q. 7, 2016-0642121C6 - 93(2.01) & Capital Contribution

contribution of shares to a subsidiary caused the subsidiary shares to be substituted property

CRA considered that the s. 93(2.01) stop loss rule applied where Canco made a contribution of capital to a foreign subsidiary (FA2) of its shares...

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Words and Phrases
substituted

18 June 2015 STEP Roundtable Q. 11, 2015-0578551C6 - 2015 STEP–Q11-Subsection 118.1(5.1)-sub property

share redemption proceeds – but not by a dividend – are substituted property

Amended s. 118.1(5.1) require that a donation be a gift of "property that was acquired by the estate on and as a consequence of the death" or...

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Words and Phrases
substituted