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ITNEWS-34-Loss Consolidation – Unanimous Shareholder Agreements

Loss Consolidation – Unanimous Shareholder Agreements In the past, the CRA has repeatedly stated that loss consolidation transactions that are legally effective and otherwise comply with the technical provisions of the Act would not ordinarily fall within the scope of section 245, provided that the transfer of income or deductions is within an affiliated group […]

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ITNEWS-34-Income Trust Reorganizations

Income Trust Reorganizations As previously stated, the typical structure for so-called income trusts is to have the trust hold all the shares and notes of a corporation. Over the last year, some mutual fund groups have announced that their group was contemplating transferring the business from the wholly owned corporation to a limited partnership in

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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

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Income Tax Folio S4-F7-C1, Amalgamations of Canadian Corporations

Income Tax Folio S4-F7-C1, Amalgamations of Canadian Corporations Series 4:  Businesses Folio 7:  Wind-ups, Dissolutions and Amalgamations Chapter 1:  Amalgamations of Canadian Corporations Summary This Chapter outlines the Canada Revenue Agency’s (CRA) views on a number of issues relating to the amalgamation of two or more taxable Canadian corporations as described in subsection 87(1) (referred to in this

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