Words and Phrases - "doctrine of merger"
disposition of surrendered stock options occurred under doctrine of merger
Two public-company predecessors by amalgamation of the taxpayer made cash payments for the surrender by employees of their options previously...
Words and Phrasesdoctrine of merger
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|Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure||payments made to target’s employees for surrendering their options on target’s acquisition were mostly deductible by it||309|
|Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) - Subparagraph 20(1)(e)(i)||quaere whether “sale” includes a sale to a 3rd party||177|
|Tax Topics - Income Tax Act - Section 111 - Subsection 111(5.2)||stock option surrender payments of target deductible under s. 111(5.2)||62|
|Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base||"cost" implies the acquisition of an asset||172|