Words and Phrases - "apply"

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14 March 2003 Internal T.I. 2003-0182977 F - 40(3.5)(c)

deeming rule in s. 40(5)(c) applies for purposes of the preconditions in s. 40(3.3) as to whether s. 40(3.4) applies

Where a public corporation ("Parentco") holding shares of a public corporation ("Subco") with an accrued loss, sells the shares to a...

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Words and Phrases
apply

7 October 2011 Roundtable, 2011-0412121C6 F - Interaction between S. 84.1 and S. 85(2.1)

s. 84.1 can "apply" and thereby prevail over s. 85(2.1) even where there is no s. 84.1 grind

Where shares with a high PUC and low ACB are transferred by an individual under s. 85(1) to Holdco for shares with the same high-low attributes,...

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Words and Phrases
apply
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 85 - Subsection 85(2.1) s. 85(2.1) does not apply where s. 84.1(1) applies even if there is no grind under the s. 84.1(1)(a) formula 166

Canada v. Cascades Inc., 2009 DTC 6122, 2009 FCA 135

"apply" does not mean "triggered results under"

The trial judge had found that the stop-loss rule in s. 40(3.4) did not apply to the disposition by the taxpayer of shares of a subsidiary ("PII")...

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Words and Phrases
apply

Collins & Aikman Products Co. v. The Queen, 2009 DTC 1179 [at 958], 2009 TCC 299, aff'd 2010 DTC 5164 [at 7293], 2010 FCA 251

limited scope of PUC provisions reflected a policy choice

The taxpayer ("Products"), which was a corporation resident in the U.S., transferred the shares of its subsidiary ("CAHL"), which was non-resident...

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Words and Phrases
apply