Words and Phrases - "merger"

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28
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Ian Bradley, Jonathan Bright, "The Stop-Loss Rules and Corporate Reorganizations – Interpretive Challenges", Canadian Tax Journal, (2019) 67:2, 383-410

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Words and Phrases
merger combination winding-up

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

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

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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 427
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 77