Subsection 256.1(6)
Administrative Policy
Income Tax Mandatory Disclosure Rules Consultation: Sample Notifiable Transactions (Finance Release Webpage), 4 February 2022
Position that attribute trading rules do not apply on the basis of the purpose tests must be notified
- The notifiable transactions designated by CRA pursuant to draft s. 237.4(3) with the concurrence of Finance include various listed transactions which are aimed at identifying situations where taxpayers rely on “one of the main reasons” or a “one of the reasons” tests in ss. 256.1(2), 256.1(4), and 256.1(6) not being satisfied so as to conclude that the “attribute trading” rules in s. 256.1(3) or 256.1(6) do not apply to transactions or events that would otherwise have satisfied all of the other conditions enumerated within those provisions.