Canadian Tax Principles (2021)
Preface
2021 Rates, Credits, and Other Data
Chapter 1 Introduction to Federal Taxation in Canada
Chapter 2 Procedures and Administration
Chapter 3 Income or Loss from an Office or Employment
Chapter 4 Taxable Income and Tax Payable for Individuals
Chapter 5 Capital Cost Allowance
Chapter 6 Income or Loss from a Business
Chapter 7 Income or Loss from Property
Chapter 8 Capital Gains and Capital Losses
Chapter 9 Other Income and Deductions, and Other Issues
Chapter 10 Retirement Savings and Other Special Income Arrangements
Chapter 11 Taxable Income and Tax Payable for Individuals Revisited
Chapter 12 Taxable Income and Tax Payable for Corporations
Chapter 13 Taxation of Corporate Investment Income
Chapter 14 Other Issues in Corporate Taxation
Chapter 15 Corporate Taxation and Management Decisions
Chapter 16 Rollovers Under Section 85
Chapter 17 Other Corporate Rollovers and Sale of a Corporate Business
Introduction Share-for-Share Exchanges—ITA 85.1 Background ITA 85.1 in Practice The ITA 85.1 Coverage General Rules Additional Conditions for the Application of ITA 85.1 Example Opting Out of ITA 85.1 Share Exchange in a Capital Reorganization—ITA 86 Application of ITA 86(1) Overview Use in Estate Freeze Qualifying for Rollover Treatment under ITA 86 General Conditions Establishing FMV for Preferred Shares The Income Tax Calculations General Rules PUC Reduction Calculation—ITA 86(2.1) Example Using ITA 86(1) in an Estate Freeze Basic Data ITA 86(1) Components The Income Tax Consequences Economic Analysis Gifting to a Related Person—ITA 86(2) Overview The Calculations Calculation of the Gift Portion PUC Reduction Other Calculations ITA 86(1) vs. ITA 85(1)—Tax Planning Considerations General Comments Use in Key Employee Successions Amalgamations—ITA 87 Amalgamations and Corporate Law Amalgamations and the ITA Predecessor Shareholders—ITA 87(4) Amalgamation Concerns Amalgamations—Tax Planning Considerations Winding-Up a 90% Owned Subsidiary—ITA 88(1) Wind-Ups and Dissolutions—Corporate Law Wind-Ups and Dissolution—The ITA Voluntary Wind-Ups and Dissolution—ITA 88(1) Subsidiary Losses—ITA 88(1.1) & 88(1.2) The Bump—ITA 88(1)(c) & 88(1)(d) Disposition of Subsidiary Shares—ITA 88(1)(b) Tax Planning Considerations—Amalgamation vs. Winding-Up Winding-Up a Canadian Corporation—ITA 88(2) Overview Income Tax Consequences—ITA 69(5), 84(2), & 88(2) Example Basic Information Cash Available for Distribution to Shareholders Distribution to Shareholders Involuntary Dissolution by Corporate Law authority Convertible Properties—ITA 51 Overview Other Exchange Considerations—ITA 51.1 & ITA 51(2) Gifting Sale of an Incorporated Business Restrictive Covenants—ITA 56.4 Overview General Rules Sale of the Business Overview Income Tax Considerations on the Sale of Corporate Property (Assets) Sale of Shares Overview & Tax Planning Considerations Example Sale of Shares for $180,000 Sale of Assets for $200,000 References Chapter 18 Partnerships
Chapter 19 Trusts and Estate Planning
Chapter 20 International Issues in Taxation
Chapter 21 GST/HST
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