Words and Phrases - "immediately before"
2014 Ruling 2014-0530371R3 - Combination of credit unions
"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...
Words and Phrases
immediately beforeLocations 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
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...
Words and Phrases
immediately beforeMacklin v. The Queen, 92 DTC 6595, [1993] 1 CTC 21 (FCTD)
"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...
Words and Phrases
immediately beforeLocations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Statutory Interpretation - Resolving Ambiguity | 53 |