237.1(1)

Income Tax Folio S7-F1-C1, Split-receipting and Deemed Fair Market Value

Income Tax Folio S7-F1-C1, Split-receipting and Deemed Fair Market Value Series 7: Charities and Non-profit Organizations Folio 1: Charitable Gifts and Deductions Chapter 1: Split-receipting and Deemed Fair Market Value Summary The purpose of this Chapter is to provide the CRA’s views on the application of subsections 248(30) to (41), which include the rules commonly referred to […]

Income Tax Folio S7-F1-C1, Split-receipting and Deemed Fair Market Value Read More »

Donation of Flow-Through Shares

Donation of Flow-Through Shares – subparagraph 38(a.1)(i), subsection 248(35) through (41) and section 237.1 Because of the flow-through nature of the deductions available to a subscriber of a flow-through share, the deemed cost of such shares to the subscriber is nil. With the elimination of capital gains taxes on shares of a public corporation donated to

Donation of Flow-Through Shares Read More »

TN-41-Definition of “tax shelter

Definition of “Tax Shelter” – Subsection 237.1(1) Briefly, in Maege v. The Queen, 15 the Federal Court of Appeal considered whether a tax shelter existed despite the absence of statements or representations directly made to a taxpayer. The Court affirmed the reasoning of the Tax Court of Canada in concluding that a tax shelter could exist in the absence

TN-41-Definition of “tax shelter Read More »

Scroll to Top
Scroll to Top