A Canadian Tax Lawyer’s Guide to s.51 Rollovers: What and How Shareholders Can Convert Equity into New Shares Without Capital Gains
Introduction: S.51 rollovers S.51 rollovers are one of the many…
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A Canadian Tax Lawyer’s Guide to Section 85 Late Filed Election
Introduction to Section 85 and Late Filed Election A transfer…
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A Canadian Tax Lawyer’s Perspective on Business Numbers Upon Amalgamation and Merger
What is an amalgamation? Amalgamation is one way in which…
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A Canadian Tax Lawyer’s Perspective on Dale et al. v The Queen -Timing On Issue Of Shares In Section 85 Rollover
Factual Background of Dale et al. v. The Queen Bernard…
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Butterfly Reorganization Leading to Third-Party Tax Liability
Introduction - Eyeball Networks Inc. v the Queen and Butterfly…
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Winding-Up A Corporation per Subsections 88(1), 88(2) & 84(2) of Income Tax Act
Introduction: Winding-up a Corporation and Corporate Law Under Part XVI…
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Section 85 Rollovers: A Canadian Tax Lawyer’s Guide
Introduction – Tax-Deferred Transfers of Property to a Corporation Section…
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Corporate Amalgamation Under Income Tax Act Section 87
Corporate Amalgamation Under Section 87 of the Income Tax Act…
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A Caution to Canadian Tax Planners: A Butterfly Reorganization Might Trigger Derivative Tax Liability under Section 160 of the Income Tax Act: Eyeball Networks Inc. v The Queen (2019 TCC 150) – A Canadian Tax Lawyer’s Analysis
Introduction: Butterfly Reorganizations & Derivative Tax Liability under Section 160…
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85.1(1) Share for Share Exchange – A Toronto Tax Lawyer Analysis
85.1(1) Share for Share Exchange – A Toronto Tax Lawyer…
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