Words and Phrases - "immediately before"

a
93
b
44
c
87
d
58
e
43
f
32
g
20
h
15
i
77
j
2
k
3
l
32
m
63
n
29
o
42
p
83
q
3
r
80
s
96
t
48
u
16
v
11
w
25
y
2

17 December 1998 External T.I. 9829565 F - ÉMISSION D'ACTION - 4900(12)

Summary Under
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(6)
“at the time the property was acquired” referenced the state of affairs before giving effect to the acquisition

The phrase “at the time the property was acquired by the trust“ in Reg. 4900(12) was interpreted as meaning immediately before rather than...

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Words and Phrases
at the time the property was acquired immediately before
Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(12) at the time of acquisition referenced immediately before rather than immediately after the acquisition 66

2014 Ruling 2014-0530371R3 - Combination of credit unions

Summary Under
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1)
"immediately before" referenced share ownership on completion of the preceding transaction in a same-day series
Proposed transactions

Acquireco and Targetco, both of which are widely-held credit unions, wish to combine their businesses to form a single...

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Words and Phrases
immediately before
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 137 - Subsection 137(4.1) s. 137(4.1) inapplicable to Buyer of credit union who winds it up rather than becoming a member 263
Tax Topics - Income Tax Act - Section 85.1 - Subsection 85.1(1) credit union share-for-share exchange/ cash redemption 52

28 November 2013 External T.I. 2013-0504221E5 F - Fin d'années réputées

Summary Under
Tax Topics - Income Tax Act - Section 249 - Subsection 249(3.1)
Amalco not a continuation of predecessors for election purposes/ "immediately before" treated as one minute before

Opco, a Canadian-controlled private corporation with a September 30 year end, amalgamates on October 1 with another CCPC so that the deemed year...

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Words and Phrases
immediately before

Macklin v. The Queen, 92 DTC 6595, [1993] 1 CTC 21 (FCTD)

Summary Under
Tax Topics - Income Tax Act - Section 44 - Subsection 44(1)
"immediately before" interpreted purposively to refer to something broader than the instant before

In August 1979 the taxpayer decided that she wished to have a portion of a farm then owned by her husband developed as a housing subdivision. In...

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Words and Phrases
immediately before
Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Resolving Ambiguity 53