Section 246.1

Table of Contents

Finance

25 September 2017 CTF Finance Roundtable, Q.11

The surplus stripping changes are intended to focus on non-arm’s length transactions, so that they would not apply, for example, where an...

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2017 CTF Finance Roundtable, Q.10

S. 246.1 was developed because the courts were not observing the scheme of the Act to prevent surplus stripping or, at least, the conversion of...

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Articles

Joint Committee, "Part D of Tax Planning Using Private Corporations – “Converting Income into Capital Gains” Proposals", 2 October 2017 Joint Committee Submission

Listing of issues under s. 246.1 (pp. 27-31)

It is unclear if, for example, there is receipt of, say, a promissory note, there is a deemed...

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Michael N. Kandev, "Proposed Section 246.1", Canadian Tax Highlights, Vol. 25, No. 8, August 2017, p.5

Breadth and harshness of proposed s. 246.1 (pp. 5-6)

New Section 246.1…as drafted,…can in theory, apply to any receipt that is a capital...

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