Words and Phrases - "on"

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5 September 2018 Internal T.I. 2017-0698241I7 - Interpretation of subsection 93(4)

FA sub shares acquired “on” disposition of FA parent shares occurring on completion of liquidation and dissolution process

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Words and Phrases
on
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 93 - Subsection 93(2.01) s. 93(2.01) applied to capital loss resulting from s. 94(3) basis bump 176
Tax Topics - Income Tax Act - Section 93 - Subsection 93(1) no s. 93 election available where ACB bump under s. 94(3) eliminated gain before application of s. 93(1) 137

10 October 2014 APFF Roundtable Q. 21, 2014-0538091C6 F - 2014 APFF Roundtable, Q. 21 - Impact of the Descarries Case

Descarries failed to recognize breadth of s. 84(2)

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Words and Phrases
on
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) Descarries failed to recognize scheme against indirect surplus stripping 696
Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) will not impose double taxation under s. 84(2) and (3) 36

David v. The Queen, 75 DTC 5136, [1975] CTC 197 (FCTD)

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Words and Phrases
on