ADMS 4562 Lecture Notes - Lecture 8: De Jure, Pro Rata, Tax Avoidance

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Topics: acquisition of control and its effect on losses, planning to utilize losses. Fit chapter 11 (11090); s. 111(4) to 111(5. 5); 249(4) Review questions 3 & 4; multiple choice questions 1 to 4; exercise 6. See: problem set (in separate document: amalgamations & windups. 17 (17070, 17110), review questions 4 and 5; multiple choice questions 1 and. Acquisition of control (aoc) and effect on losses and planning to utilize losses. Scenario: control of a corporation is acquired because shares are purchased i. e. , more than 50% of the voting shares are acquired by a person or group (de jure control)* *if shares are purchased from a related person then there will not be an aoc [subsection. Starting march 21, 2013 and thereafter, there will be a deemed aoc when more than 75% of the. Fmv of all shares of a corporation have been acquired from an arm"s length person (but there has not been an aoc).

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