Words and Phrases - "substituted"
22 June 2016 Internal T.I. 2016-0632821I7 F - 93(2.01) & Capital Contribution
ordinary meaning of “substituted”
Canco contributed (for no share consideration) its shares of a non-resident Finco subsidiary (Luxco2 – which previously had paid exempt...
Words and Phrases
substituted| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 93 - Subsection 93(2.01) | a contribution of FA1 shares to FA2 causes the FA2 shares to be substituted property for s. 93(2.01) purposes | 195 |
| Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(a) - Subparagraph 95(2)(a)(ii) - Clause 95(2)(a)(ii)(B) | inter-affiliate loan generating deemed active business funded out of an interest-free loan from Canco | 105 |
26 May 2016 IFA Roundtable Q. 7, 2016-0642121C6 - 93(2.01) & Capital Contribution
contribution of shares to a subsidiary caused the subsidiary shares to be substituted property
CRA considered that the s. 93(2.01) stop loss rule applied where Canco made a contribution of capital to a foreign subsidiary (FA2) of its shares...
Words and Phrases
substituted18 June 2015 STEP Roundtable Q. 11, 2015-0578551C6 - 2015 STEPQ11-Subsection 118.1(5.1)-sub property
share redemption proceeds – but not by a dividend – are substituted property
Amended s. 118.1(5.1) require that a donation be a gift of "property that was acquired by the estate on and as a consequence of the death" or...
Words and Phrases
substituted