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Cropper 1889 14 App Cas 525 HL
90 other sections not shown
acquired acquisition adjusted cost base agreement amalgamation amended amount apply arm's length assets beneficiary benefit British Columbia buy-sell buy-sell agreement Canada Round Table Canadian Tax Foundation capital cost allowance capital dividend account capital gains exemption capital loss capital property cash CCPC common shares corporation's court deal at arm's debt deemed dividend determined election employee example fair market value FCTD federal Holdco holding company included Income Tax incorporation individual interest Interpretation Bulletin investment issued liability loan Newco non-resident Ontario Opco paid paid-up capital paragraph particular corporation partnership payment percent person preferred shares private corporation provides provincial purchase pursuant Quebec Quebec Act received respect result Revenue Canada Round rollover RRSP rules safe income section 85 shareholder small business deduction spouse subparagraph subsection 55(2 subsidiary supra footnote Tax Conference tax credit tax purposes taxable dividend taxable income taxation taxpayer transaction transfer trust vendor Yes Yes Yes