Commentary: 84(1)
84(1) – Coming Soon
84
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
Income Tax Folio S4-F7-C1, Amalgamations of Canadian Corporations Read More »
Income Tax Folio S4-F8-C1, Business Investment Losses
Series 4: Businesses Folio 8: Losses Chapter 1: Business Investment Losses Summary A taxpayer’s business investment loss is basically a capital loss from a disposition of shares in, or a debt owing to the taxpayer by, a small business corporation (SBC) where the disposition is: to an arm’s-length person; or one to which subsection 50(1) applies. One-half of this loss
Income Tax Folio S4-F8-C1, Business Investment Losses Read More »
Income Tax Folio S3-F6-C1, Interest Deductibility
Income Tax Folio S3-F6-C1, Interest Deductibility Series 3: Property, Investments, and Savings Plans Folio 6: Interest Chapter 1: Interest Deductibility Summary The purpose of this Chapter is to explain the Canada Revenue Agency’s (CRA) position on the deductibility of interest expense under paragraph 20(1)(c). The Chapter also discusses various other provisions of the Act relating to interest deductibility. An amount
Income Tax Folio S3-F6-C1, Interest Deductibility Read More »
Income Tax Folio S4-F3-C1, Price Adjustment Clauses
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
Income Tax Folio S4-F3-C1, Price Adjustment Clauses Read More »
Income Tax Folio S4-F5-C1, Share for Share Exchange
Income Tax Folio S4-F5-C1, Share for Share Exchange Series 4: Businesses Folio 5: Tax Deferred Rollovers Chapter 1: Share for Share Exchange Summary This Chapter discusses the rules applicable to a share for share exchange carried out under section 85.1. The rules apply in certain circumstances when a taxable Canadian corporation is acquired by a Canadian corporation.
Income Tax Folio S4-F5-C1, Share for Share Exchange Read More »
ITNEWS-34-Income Earned or Realized – The Kruco Case
Income Earned or Realized – The Kruco Case Subsection 55(2) of the Income Tax Act (the “Act”) is an anti-avoidance provision directed against arrangements designed to use the inter-corporate dividend exemption to reduce a capital gain on the sale of a share. Subsection 55(2) will generally apply where the purpose of the dividend (or the result in the case
ITNEWS-34-Income Earned or Realized – The Kruco Case Read More »
IT67R3- Taxable dividends from corporations resident in Canada
IT SUBJECT: INCOME TAX ACT Taxable Dividends from Corporations Resident in Canada No: IT-67R3 DATE: May 15, 1992 REFERENCE: Paragraph 12(1)(j) (also sections 82, 83, 84, 84.1 and 121; subsections 153(4), 260(5); the definition of “dividend”, “stock dividend” and “dividend rental arrangement” in subsection 248(1); and paragraph 89(1)(j)) Application This bulletin replaces and cancels Interpretation
IT67R3- Taxable dividends from corporations resident in Canada Read More »
IT149R4- Winding-up Dividend
NO: IT149R4 DATE: June 28, 1991 SUBJECT: INCOME TAX ACT Winding-up Dividend REFERENCE: Subsection 88(2) (also subsections 83(2), 84(2), 133(7.1), paragraph 148(9)(a) and subparagraphs 54(h)(ix), 89(1)(b)(iv) and (v)) Application This bulletin replaces and cancels Interpretation Bulletin IT-149R3 dated July 22, 1985. Current revisions are designated by vertical lines. Summary This bulletin discusses the “winding-up dividend” that
IT146R4- Shares Entitling Shareholders to Choose Taxable or Capital Dividends
NO: IT-146R4 DATE: September 6, 1991 SUBJECT: INCOME TAX ACT Shares Entitling Shareholders to Choose Taxable or Capital Dividends REFERENCE: Paragraph 54(c) (also sections 51, 83 and 86, subsection 84(3) and paragraph 89(1)(j)) Application This bulletin replaces and cancels Interpretation Bulletin IT-146R3 dated August 25, 1980. Current revisions are designated by vertical lines. Summary This bulletin
IT146R4- Shares Entitling Shareholders to Choose Taxable or Capital Dividends Read More »