NO.: IT-115r2 DATE: February 20, 1995 SUBJECT: INCOME TAX ACT Fractional Interest in Shares REFERENCE: Subsection 51(1) (also section 47 and subsections 51(2) and (4) of the Income Tax Act and subsection 26(8) of the Income Tax Application Rules (ITAR)) Application This bulletin cancels and replaces Interpretation Bulletin IT-115R dated September 15, 1975. Summary Section 51 sets out the rules concerning convertible property. Subsection 51(1) […]
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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Income Tax Folio S4-F3-C1, Price Adjustment Clauses Series 4: Businesses Folio 3: General Principles of Business Income Calculation Chapter 1: Price Adjustment Clauses Summary A price adjustment clause is typically incorporated into an agreement entered into by non-arm’s-length persons to provide for an adjustment to the transaction price in the event that a third-party such as
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