Words and Phrases - "formed"

a
85
b
44
c
76
d
50
e
38
f
31
g
18
h
14
i
72
j
2
k
2
l
32
m
55
n
25
o
38
p
79
q
3
r
76
s
88
t
46
u
15
v
9
w
22
y
2

26 January 2018 Internal T.I. 2017-0735771I7 - Application of paragraph 40(3.5)(c)

Summary Under
Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.5) - Paragraph 40(3.5)(c) - Subparagraph 40(3.5)(c)(i)
a suspended loss on the sale of CFA1 to CFA2 was not de-suspended on s. 95(2)(e) wind-up of CFA1 into CFA2

ACo, a Canadian public corporation, held the shares of three controlled foreign affiliates (CCo, DCo and BCo directly. Shares (that were excluded...

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Words and Phrases
merger formed
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.5) - Paragraph 40(3.5)(b) scope of s. 40(3.5)(b) extends to mergers and constructive formation of new entities 443
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(e) S. 95(2)(e) wind-up constructively resulted in formation of new corporation 79

16 May 2018 IFA Roundtable Q. 5, 2018-0745501C6 - Meaning of “merged or combined” in 40(3.5)(c)(i)

Summary Under
Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.5) - Paragraph 40(3.5)(c) - Subparagraph 40(3.5)(c)(i)
suspended loss on the sale of CFA to Subco was not de-suspended on s. 88(3) wind-up of CFA

Canco sold all the shares of FA to Canco’s wholly-owned subsidiary (Subco) and realized a capital loss that was suspended under s. 40(3.4). In...

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Words and Phrases
merged or combined formed
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 88 - Subsection 88(3) s. 88(3) wind-up of CFA formed a new corporation 173