Form T2107 "Election for a Disposition of Shares in a Foreign Affiliate" - Canada

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Download Form T2107 "Election for a Disposition of Shares in a Foreign Affiliate" - Canada

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Election for a Disposition of Shares in a Foreign Affiliate
For use by a corporation resident in Canada to elect under subsection 93(1) of the Income Tax Act for
Do not use this area
the disposition of shares in a foreign affiliate or such disposition by another foreign affiliate.
Separate elections must be made when a disposition of shares in a foreign affiliate involves shares of
different classes or when dispositions are made at different times.
Mail one completed copy of this election (plus attachments), separately from any tax return, to your tax
centre by the due date identified in subsection 5902(5) of the Income Tax Regulations.
Find your tax centre's address at www.cra.gc.ca/tso.
For late-filed or amended elections, mail one completed copy of this election (plus attachments) to your
tax centre.
Surplus calculations must be filed with this election (see
note 2
on page 2).
Tax year-end
Corporation's name
Resident
Year
Month
Day
corporation
filing this
Address
Business number
election
Tax year-end
Corporation's name
Disposing corporation
(if different from resident
Year
Month
Day
corporation must be a foreign
affiliate of the resident
Address
Business number
corporation)
Corporation's name
Foreign affiliate
whose shares
have been
Address
disposed of
Penalty for late-filed and amended elections
Late-filed election – subsection 93(5) – we will accept an election filed within three years after the due date and consider it to have been filed on the
due date, provided an estimate of the penalty described in subsection 93(6) is paid at the time of filing the election.
Special cases – subsection 93(5.1) – we may accept an election filed after the three-year due date or an amended election. At the discretion of the
Minister, if it is considered just and equitable to do so, the late or amended election will be considered to have been filed by the due date, provided an
estimate of the penalty described in subsection 93(6) is paid at the time of filing the election. A written submission setting out reasons supporting the
acceptance of this election should accompany the election.
Calculation of late-filed penalty:
Do not use this area
=
×
. . . . . . . . . . .
number of shares disposed
elected amount per share
total elected amount
= . . . . . . . . .
1
× ¼ × 1 % × N
total elected amount
*
2
×
$100
N
*
(maximum $8,000). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
A
Estimate of late-filing penalty is the lesser of 1 and 2 above . . . . . . . . . . . . .
* N represents the sum of each month or each part of a month in the period from the
election's due date to the actual filing date.
Attach cheque or money order payable to the Receiver General, if a penalty is payable. Specify T2107
on the remittance and indicate the name and business number of the corporation whose account is to
be credited.
Amount enclosed
T2107 E (15)
(Vous pouvez obtenir ce formulaire en français à www.arc.gc.ca/formulaires ou en composant le 1-800-959-7775.)
Page 1 of 2
Clear Data
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Protected B
when completed
Election for a Disposition of Shares in a Foreign Affiliate
For use by a corporation resident in Canada to elect under subsection 93(1) of the Income Tax Act for
Do not use this area
the disposition of shares in a foreign affiliate or such disposition by another foreign affiliate.
Separate elections must be made when a disposition of shares in a foreign affiliate involves shares of
different classes or when dispositions are made at different times.
Mail one completed copy of this election (plus attachments), separately from any tax return, to your tax
centre by the due date identified in subsection 5902(5) of the Income Tax Regulations.
Find your tax centre's address at www.cra.gc.ca/tso.
For late-filed or amended elections, mail one completed copy of this election (plus attachments) to your
tax centre.
Surplus calculations must be filed with this election (see
note 2
on page 2).
Tax year-end
Corporation's name
Resident
Year
Month
Day
corporation
filing this
Address
Business number
election
Tax year-end
Corporation's name
Disposing corporation
(if different from resident
Year
Month
Day
corporation must be a foreign
affiliate of the resident
Address
Business number
corporation)
Corporation's name
Foreign affiliate
whose shares
have been
Address
disposed of
Penalty for late-filed and amended elections
Late-filed election – subsection 93(5) – we will accept an election filed within three years after the due date and consider it to have been filed on the
due date, provided an estimate of the penalty described in subsection 93(6) is paid at the time of filing the election.
Special cases – subsection 93(5.1) – we may accept an election filed after the three-year due date or an amended election. At the discretion of the
Minister, if it is considered just and equitable to do so, the late or amended election will be considered to have been filed by the due date, provided an
estimate of the penalty described in subsection 93(6) is paid at the time of filing the election. A written submission setting out reasons supporting the
acceptance of this election should accompany the election.
Calculation of late-filed penalty:
Do not use this area
=
×
. . . . . . . . . . .
number of shares disposed
elected amount per share
total elected amount
= . . . . . . . . .
1
× ¼ × 1 % × N
total elected amount
*
2
×
$100
N
*
(maximum $8,000). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
A
Estimate of late-filing penalty is the lesser of 1 and 2 above . . . . . . . . . . . . .
* N represents the sum of each month or each part of a month in the period from the
election's due date to the actual filing date.
Attach cheque or money order payable to the Receiver General, if a penalty is payable. Specify T2107
on the remittance and indicate the name and business number of the corporation whose account is to
be credited.
Amount enclosed
T2107 E (15)
(Vous pouvez obtenir ce formulaire en français à www.arc.gc.ca/formulaires ou en composant le 1-800-959-7775.)
Page 1 of 2
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Protected B
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Particulars of disposition for which an election is made
Class of capital stock (detailed description)
Number of shares disposed of
Date of disposition
Elected amount per share
(note 1)
Proceeds per share
Gain from the disposition of share after August 19, 2011
Adjusted cost per share
Balance of exempt surplus at time of disposition
Balance of taxable surplus (if any) at time of disposition
Specify the amounts entered above in Canadian currency.
Notes
1. Is the amount designated in this election based on a determination of one or more fair market values?
Yes
No
2. You have to file with this election a calculation of the balance of exempt surplus and balance of taxable surplus (if any) at the time of
disposition. Income Tax Regulation 5902 contains the rules for calculating the required surplus balances. You do not need to submit
documentation to support these balances, but you have to keep it in case we ask for it.
Election and certification
The resident corporation elects to have the provisions of subsection 93(1) of the Income Tax Act apply for the disposition of the shares shown on
this form.
I certify that the information given in this election and in all attached documents is correct and complete.
Name of authorized officer of the corporation
Position or title of officer
Date yyyy-mm-dd
Signature of authorized officer of the corporation
Privacy Statement
Personal information is collected under the Income Tax Act to administer tax, benefits, and related programs. It may also be used for any purpose
related to the administration or enforcement of the Act such as audit, compliance and the payment of debts owed to the Crown. It may be shared or
verified with other federal, provincial/territorial government institutions to the extent authorized by law. Failure to provide this information may result in
interest payable, penalties or other actions. Under the Privacy Act, individuals have the right to access their personal information and request correction
if there are errors or omissions. Refer to Info Source at www.cra.gc.ca/gncy/tp/nfsrc/nfsrc-eng.html, Personal Information Bank CRA PPU 047.
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