Product details

Publisher: 
Carswell
Practice area: 
Tax & accounting
Jurisdiction: 
General
Publication date: 
2017-01-01
Carswell

Taxation of Corporate Reorganizations (looseleaf service)

Author: Kim Brooks
Availability: In Stock

Taxation of Corporate Reorganizations provides a comprehensive review of all aspects of the taxation of corporate reorganizations in Canada, including related issues. The publication provides context and analysis on preliminary matters, like classifications of corporations and the application of the general anti-avoidance rule. Separate chapters discuss the transfer of property to a corporation, capital transactions, amalgamations, wind-ups, and split-ups. The volumes also include a section-by-section commentary on the taxation landscape and provide a review of the transformation of a branch, including treaty issues.

Specific topics included in the text

  • Consequences of section 51; non-arm’s length sale of shares (section 84.1); exchange of shares by a shareholder in the course of reorganization of capital (section 86); foreign spin-offs (section 86.1); and non-arm’s length sale of shares by non-residents (section 212.1)
  • In Pomerleau c. La Reine, further commentary has been added regarding Justice Favreau’s decision being upheld by the Federal Court of Appeal. Updated commentary has been added regarding 1245989 Alberta Ltd. v. R.; Perry Wild v. R., as the decision was reversed by the Federal Court of Appeal
Carswell

Taxation of Corporate Reorganizations (looseleaf service)

Author: Kim Brooks
Availability: In Stock

Description

Taxation of Corporate Reorganizations provides a comprehensive review of all aspects of the taxation of corporate reorganizations in Canada, including related issues. The publication provides context and analysis on preliminary matters, like classifications of corporations and the application of the general anti-avoidance rule. Separate chapters discuss the transfer of property to a corporation, capital transactions, amalgamations, wind-ups, and split-ups. The volumes also include a section-by-section commentary on the taxation landscape and provide a review of the transformation of a branch, including treaty issues.

Specific topics included in the text

  • Consequences of section 51; non-arm’s length sale of shares (section 84.1); exchange of shares by a shareholder in the course of reorganization of capital (section 86); foreign spin-offs (section 86.1); and non-arm’s length sale of shares by non-residents (section 212.1)
  • In Pomerleau c. La Reine, further commentary has been added regarding Justice Favreau’s decision being upheld by the Federal Court of Appeal. Updated commentary has been added regarding 1245989 Alberta Ltd. v. R.; Perry Wild v. R., as the decision was reversed by the Federal Court of Appeal