Question
Assume that Company A is a wholly owned subsidiary of Company B and there is an accrued capital gain on the shares of Company A
Assume that Company A is a wholly owned subsidiary of Company B and there is an accrued capital gain on the shares of Company A held by Company B. All of the following are conditions required for the application of the capital gains stripping rules under ITA55(2), except
Company B receives dividends that qualify as a division"C" deduction, as part of a transaction involving the disposition of the Company A shares held by Company B.
B.
Company B receives dividends from Company A and the purpose of the dividend is to reduce the capital gain on the disposition of Company A shares.
C.
Company B transfers the shares of Company A to a holding company under ITA 85 and takes back preferred shares of the holding company as consideration on the transfer.
D.
Company B disposes of the Company A shares and the disposition of shares is to anarm's length party.
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