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...
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...
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...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 84.1 - Subsection 84.1(2) - Paragraph 84.1(2)(a.1) | 612 |
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...