Canada: Capital Gains Tax

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Article
Property Transfers And Flipped Property Rules Under Section 85 Of The ITA: A Welcome Flexibility For Internal Reorganizations
The flipped property rules in the federal Income Tax Act (“ITA”) have raised many questions regarding property transfers since they came into effect. Although these rules were initially designed to curb property flipping, they are broad in scope and can sometimes affect non-speculative transactions, as discussed in a previous article: Navigating the federal flipped property rule. In response, the Canada Revenue Agency (“CRA”) has since published a number of interpretation bulletins clarifying the rules, including their interaction with property transfers under section 85 of the ITA.
Canada Tax
MT
Miller Thomson LLP
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