SUBJECT INDEX :
2.4 Capital Gains

TI2011-0417481E5 - 2012/03/26 - Financial Industries Division of the Rulings Directorate

In this TI, the taxpayer seeks comments from CRA on the treatment of property that has been severed from a principal residence. The principal residence lot is larger than what would be considered a normal residential lot due to minimum lot size laws or reg...

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The Hache decision of Justice Lamarre of the Tax Court of Canada (2010TCC10...

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TI2009-0310251E5 was issued 09/09/17 by the Corporate Reorganizations Division.

 In this French language TI, CRA considers the interaction of section 89 (capital dividend account) and 55 (deemed capital gain) of th...

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TI2008-0297871E5 was issued 09/01/21 by the Business and Partnerships Division of the Rulings Directorate

The straightforward question posed is whether two parcels of farmland, with both names of two brothers on each title, can be partitioned so that only one name will remain on each parcel without any tax conseque...

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TI2008-0263781E5 was issued 08/02/25 by the Business and Partnerships Division of the Rulings Directorate.

This TI discusses a fairly common fact pattern:  the taxpayer lived on an 8-acre property that was owned and used as their principal residence since acquisition.  The municipal laws require the parce...

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Over the past few months, David Louis of Minden Gross has written two articles on the "Vancouver Control Premium" issue.  If your clients are Ma and Pa shareholders of a private company holding, as is often the case, with 50 common voting shares with sprinkling or exclusionary dividend rights held by Pa and 50 non-voting common shares with similar dividend rights held by Ma, you could be i...

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The Guy Laflamme decision of the Justice Lucille Lamarre of the Tax Court of Canada (2008TCC255) represents an interesting case study in estate planning, share rights and restrictions and valuation principles.  While the facts are very complex , there are some notable observations by the court with...

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TI20080275451I7 was issued 08/06/24 by the Business and Partnerships Division of the Rulings Directorate.

This rather lengthy TI contains a good discussion of CRA’s views on whether the gain realized on the sale of farm land was on account of capital or income, and whether the family tax planning that was undertak...

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