28 January 2021 Internal T.I. 2019-0817641I7 - Acquisition of rights to pension surplus
A portion of the purchase price paid for the acquisition of a business of the Seller by the Purchaser was allocated to the actuarial surplus in a...
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|Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e)||purchased actuarial surplus was a reserve||195|
|Tax Topics - Income Tax Act - Section 78 - Subsection 78(4)||s. 78(4) exclusion would apply to the purchase of actuarial surplus||191|
|Tax Topics - Income Tax Act - Section 13 - Subsection 13(35)||purchased actuarial surplus was not deemed goodwill under s. 13(35)||222|