Administrative Policy
2003 Ruling 2003-0007243 - XXXXXXXXXX - Mutual Fund
Various series of shares of a mutual fund corporation are redeemable by their holders for the net asset value per class, and are exchangeable for...
Subsection 6202.1(1)
Cases
Canada v. JES Investments Ltd., 2007 DTC 5608, 2007 FCA 337
An exploration company ("Deena") that entered into an agreement styled as a flow-through share agreement with the taxpayer failed to incur any...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 66 - Subsection 66(15) - Flow-Through Share | 107 |
See Also
Furukawa v. R., 99 DTC 474, [1999] 2 CTC 2095 (TCC), aff'd 2000 DTC 6669 (FCA)
Various "sweeteners" provided by the issuer of what otherwise would be flow-through shares, namely, lifetime playing privileges and a building lot...
Administrative Policy
2012 Ruling 2012-0466731R3 - Donation of flow-through shares
Donors (mostly Canadian-resident individuals) as well as non-donors use cash to subscribe for flow-through shares of a listed Canadian resource...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts | 235 |
94 C.P.T.J. - Q. 12
A right of recission potentially accorded by securities laws in respect of a misrepresentation in a prospectus generally would not, by itself,...
17 October 1991 T.I. (Tax Window, No. 11, p. 9, ¶1527)
An agreement of the corporation giving it the right, but not the obligation, to acquire the shares for the amount determined by the corporate...
90 C.P.T.J. - Q.7; 91 C.P.T.J. - Q.19
Where an issuer agrees to pay damages to the subscriber only to the extent of any additional tax payable by the subscriber as a consequence of a...
90 C.R. - Q. 48
An indemnity by the issuer of flow-through shares to pay tax payable by the subscriber as a consequence of a failure to renounce will not cause...
16 March 1990 T.I. (August 1990 Access Letter, ¶1373)
Detailed discussion.
88 C.R. - Q. 25
The agreement of the issuer of the share to pay damages to the subscriber to the extent of any additional tax payable by the subscriber as a...
Paragraph 6202.1(1)(b)
Administrative Policy
9 December 2020 External T.I. 2020-0852321E5 - Flow Through Shares - Fees Paid to Promoter
A principal-business corporation (the “Issuer”) issues publicly-listed shares pursuant to flow-through share agreements to individual...
Paragraph 6202.1(1)(c)
Articles
Gregory M. Johnson, Wesley R. Novotny, "An Update on Flow-through Shares in the Energy Sector", 2016 Conference Report (Canadian Tax Foundation),12:1-39
No need to contractually preclude general common law right to sue (p. 12:23)
Most provinces have certain statutory rights of rescission. …
All...
Paragraph 6202.1(1)(d)
Articles
Gregory M. Johnson, Wesley R. Novotny, "An Update on Flow-through Shares in the Energy Sector", 2016 Conference Report (Canadian Tax Foundation),12:1-39
Potential issue if flow-through share issued after signing of merger agreement (pp 12:17-18)
Regulation 6202.1(1)(d) could result in a...
Subsection 6202.1(1.1)
Paragraph 6202.1(1.1)(c)
Articles
Gregory M. Johnson, Wesley R. Novotny, "An Update on Flow-through Shares in the Energy Sector", 2016 Conference Report (Canadian Tax Foundation),12:1-39
Prescribed share issues if flow-through subscription receipts (p. 12:21-22)
[I]f the subscription agreement for subscription receipts were...
Subsection 6202.1(2)
Paragraph 6202.1(2)(b)
Administrative Policy
21 November 2013 External T.I. 2013-0497641E5 - Flow-through shares and stock options
An employee of a principal-business corporation is granted a stock option, at no cost, to purchase shares of the PBC at a specified exercise...
Subsection 6202.1(5)
Excluded Obligation
Articles
Gregory M. Johnson, Wesley R. Novotny, "An Update on Flow-through Shares in the Energy Sector", 2016 Conference Report (Canadian Tax Foundation),12:1-39
No need to contractually preclude general common law right to sue (p. 12:23)
Most provinces have certain statutory rights of rescission. …
All...