28 May 2015 IFA Roundtable Q. 10, 2015-0581641C6 - IFA 2015 Q.10: 111(4)(e) election and 212.3 -- summary under Paragraph 212.3(18)(a)

Following the acquisition of control of the non-resident parent of a CRIC, the CRIC made a s. 111(4)(e) designation respecting its 100% shareholding of its FA. Before going on to find that the resulting deemed dividend under 212.3(2)(a) would be nil, CRA stated:

[T]he subparagraph 111(4)(e)(ii) deemed reacquisition of the FA shares by the… CRIC would constitute an "investment in a subject corporation made by a CRIC" as described in paragraph 212.3(10)(a) and would not be an investment described in paragraph 212.3(18)(a) given that the CRIC would not be related to itself. …

See summary under s. 212.3(2).

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Topic
Income Tax Act - s. 212.3(18)(a)
Tagline
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
319328
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
343748
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