Words and Phrases - "substituted"

a
88
b
44
c
78
d
52
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

22 June 2016 Internal T.I. 2016-0632821I7 F - 93(2.01) & Capital Contribution

Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(5)
ordinary meaning of “substituted”

Canco contributed (for no share consideration) its shares of a non-resident Finco subsidiary (Luxco2 – which previously had paid exempt...

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Words and Phrases
substituted

26 May 2016 IFA Roundtable Q. 7, 2016-0642121C6 - 93(2.01) & Capital Contribution

Summary Under
Tax Topics - Income Tax Act - Section 93 - Subsection 93(2.01)
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...

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Words and Phrases
substituted

18 June 2015 STEP Roundtable Q. 11, 2015-0578551C6 - 2015 STEP–Q11-Subsection 118.1(5.1)-sub property

Summary Under
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(5.1)
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...

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Words and Phrases
substituted