Canadian Tax Journal, Volume 23; Volume 23

acquired active business adjusted cost base amount appeal apply assessment assets Bill Budget Canadian Tax Foundation Canadian Tax Journal capital cost allowance capital gain capital loss capital property capital surplus changes clause common shares contributed surplus corporation Court CSOH debt deduction deemed dividend development expenses dividend stripping effect election estate freeze Excise exemption expenditures fair market value federal fees Finance fiscal Freezor's funds gazetted H Ltd HoCo included Income Tax Act increase interest investment issued ment Minister non-resident November 18 OECD Ontario OpCo shares paid paid-up capital deficiency paragraph parties partnership payable payment plaintiff preference shares proceeds of disposition profits provincial provisions PUCD purchase purposes Quebec question received referred refund regulations resident resource property respect result Revenue Canada rollover RRSP rules sales tax section 85 shareholder subparagraph tax credit tax haven tax-free taxation taxpayer tion transaction transfer transferor treaty winding-up