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Summary of Provisions
Increased Shareholdings and Mergers
Appendix A t
2 other sections not shown
accrual property income acquiring aﬁiliate active business carried active business income adjusted cost base affiliate aﬂiliate’s amount deducted amount equal amount in respect beneﬁciary calculated Canadian corporation Canadian taxpayer capital loss capital stock class of shares controlled foreign aﬂiliate corporation resident corporation’s deducted in computing deductible in respect deemed paid direct equity percentage discretionary trusts disposition of shares distribution entitlement dividend deemed dividend received earnings amount exceeds the aggregate exempt deﬁcit exempt earnings exempt loss exempt surplus fair market value FAPI ﬁrst foreign accrual property foreign afﬁliate income or proﬁts issued shares merger non-resident corporation Paragraph 95(2 participating percentage payable portion pre-acquisition surplus proceeds of disposition proﬁts tax paid provides reasonably be regarded resident in Canada Rule shareholders shares of Corporation subsection 91(1 surplus in respect taxable deﬁcit taxable earnings taxable income taxable loss taxable surplus taxpayer resident tion trust underlying foreign tax virtue of subsection withholding tax