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CPAstore - Canadian Tax Principles - Professional Edition

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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