Words and Phrases - "immediately before"

a
88
b
44
c
80
d
53
e
38
f
31
g
19
h
14
i
74
j
2
k
2
l
32
m
56
n
25
o
38
p
81
q
3
r
76
s
90
t
47
u
16
v
9
w
23
y
2

2014 Ruling 2014-0530371R3 - Combination of credit unions

Summary Under
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1)
"immediately before" referenced share ownership on completion of the preceding transaction in a same-day series
Proposed transactions

Acquireco and Targetco, both of which are widely-held credit unions, wish to combine their businesses to form a single...

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Words and Phrases
immediately before
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 137 - Subsection 137(4.1) s. 137(4.1) inapplicable to Buyer of credit union who winds it up rather than becoming a member 263
Tax Topics - Income Tax Act - Section 85.1 - Subsection 85.1(1) credit union share-for-share exchange/ cash redemption 52

28 November 2013 External T.I. 2013-0504221E5 F - Fin d'années réputées

Summary Under
Tax Topics - Income Tax Act - Section 249 - Subsection 249(3.1)
Amalco not a continuation of predecessors for election purposes/ "immediately before" treated as one minute before

Opco, a Canadian-controlled private corporation with a September 30 year end, amalgamates on October 1 with another CCPC so that the deemed year...

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Words and Phrases
immediately before

Macklin v. The Queen, 92 DTC 6595, [1993] 1 CTC 21 (FCTD)

Summary Under
Tax Topics - Income Tax Act - Section 44 - Subsection 44(1)
"immediately before" interpreted purposively to refer to something broader than the instant before

In August 1979 the taxpayer decided that she wished to have a portion of a farm then owned by her husband developed as a housing subdivision. In...

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Words and Phrases
immediately before
Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Resolving Ambiguity 53