Paragraph 38(a.1)
Administrative Policy
2015 Ruling 2014-0532201R3 - Corporate reorganization
Background
This reorganization concerns a Canadian corporate group for which five named individuals (B to F), a spousal trust for D and four...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 84 - Subsection 84(3) | cancellation of upstream shareholding on s. 88(1) wind-up | 65 |
| Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts | donation and sale-back of public company shares | 84 |
Paragraph 38(a.2)
See Also
Staltari v. The Queen, 2015 DTC 1130 [at 818], 2015 TCC 123
A commercial real estate broker donated land to the City of Ottawa, received a charitable receipt for its appraised value and claimed that his...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Evidence | uncorroborated testimony | 99 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business | no business where no business organization | 167 |
| Tax Topics - Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(a) | exclusion of gains that are ordinary income | 149 |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | secondary intention to develop land irrelevant if land donated instead | 500 |