Subsection 136(1)
Administrative Policy
12 July 2000 Internal T.I. 2000-0027857 F - PDTPE - COOPÉRATIVE
Regarding whether the members of a cooperative could claim an allowable business investment loss respecting their shares in the cooperative...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(c) | s. 50(1) ABIL could be claimed on members’ shares of cooperative in reliance on 12-month SBC lookback rule | 289 |
Subsection 136(2)
Administrative Policy
6 October 2005 External T.I. 2005-0146061E5 F - Coop de travailleurs actionnaire - montants versés
Regarding the qualification of a workers shareholder cooperative, CRA stated:
As stated in F9902745 … a workers cooperative provides services to...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 82 - Subsection 82(1) - Paragraph 82(1)(a) | interest on a preferred share was a dividend | 27 |
| Tax Topics - Income Tax Act - Section 135 - Subsection 135(4) - Allocation in Proportion to Patronage | patronage dividend based on volume of work performed | 108 |
Paragraph 136(2)(c)
Administrative Policy
6 November 2015 External T.I. 2015-0611691E5 F - Member of a cooperative corporation
What is the meaning of “member” for purposes of s. 136(2)(c)? Does the s. 135(4) definition apply? CRA responded:
[T]he preamble to...
Words and Phrases
member29 May 2001 Internal T.I. 2000-0053257 F - COOPERATIVE
Where an individual ceased being a member of a cooperative (although still owning preferred shares thereof) but became a partner in a partnership,...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 136 - Subsection 136(2) - Paragraph 136(2)(d) | shares need not be fully paid | 44 |
Paragraph 136(2)(d)
Administrative Policy
29 May 2001 Internal T.I. 2000-0053257 F - COOPERATIVE
The Directorate indicated that shares for purposes of s. 136(2)(d) would include shares that had been subscribed for by the member but not fully...
Words and Phrases
share| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 136 - Subsection 136(2) - Paragraph 136(2)(c) | non-member individual cannot look through a farming member partnership | 79 |