84(3)

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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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

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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

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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

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