http://blog.simpsonwigle.com/2010/03/84-1-gotcha/ Tax News for Owner/Managers and Their Advisers Tue, 07 Feb 2012 15:27:50 +0000 hourly 1 http://wordpress.org/?v=3.3.1 http://blog.simpsonwigle.com/2010/03/84-1-gotcha/comment-page-1/#comment-55641 John Loukidelis Fri, 12 Mar 2010 21:28:44 +0000 http://blog.simpsonwigle.com/?p=649#comment-55641 Myron, this is generally true. I believe that, in the bad old days, taking back shares with too much PUC could result in a deemed dividend, but paragraph 84.1(1)(a) now automatically grinds the PUC of new shares to the greater of the PUC of the old shares and their "hard" basis. Myron, this is generally true. I believe that, in the bad old days, taking back shares with too much PUC could result in a deemed dividend, but paragraph 84.1(1)(a) now automatically grinds the PUC of new shares to the greater of the PUC of the old shares and their “hard” basis.

]]> http://blog.simpsonwigle.com/2010/03/84-1-gotcha/comment-page-1/#comment-55640 Myron Triska Fri, 12 Mar 2010 17:51:23 +0000 http://blog.simpsonwigle.com/?p=649#comment-55640 John, I assume this whole trasaction, exactly as it is, would be fine with no s 84.1 problem, if there was no "boot"involved? John, I assume this whole trasaction, exactly as it is, would be fine with no s 84.1 problem, if there was no “boot”involved?

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