Words and Phrases - "dividend"
9 May 2002 Internal T.I. 2002-0135307 F - Application du paragraphe 39(2)
Before going on to find that if a distribution made from a Delaware subsidiary’s surplus would be a dividend for ITA purposes if it was a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 90 - Subsection 90(3) | distribution of contributed surplus by Delaware subsidiary likely was a dividend | 61 |
| Tax Topics - Income Tax Act - Section 39 - Subsection 39(2) | distribution by Delaware subsidiary that did not result in s. 40 application thereby did not engage s. 39(2) | 100 |
Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114
Most pro rata corporate distributions are dividends (pp. 20:16-17)
Cangro Resources … held that for the purposes of the Act, “dividend” was...
Cangro Resources Ltd. v. MNR, 67 DTC 582 (TAB)
A payment received by the taxpayer that was stated to be made out of "paid-in capital and paid-in surplus" pursuant to the provisions of the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | 118 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Dividend | distributions out of share premium based on number of shares held were dividends | 231 |
Guilder News Co. (1963) Ltd. v. MNR, 73 DTC 5048, [1973] CTC 1 (FCA)
At 5053:
"[M]any of the amounts that would fall under section [15(1)] would not fall within the concept of 'dividend' in its ordinary sense in...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Effective Date | 229 | |
| Tax Topics - Income Tax Act - Section 121 | 13 | |
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | restoration of previous year's detriment was benefit | 231 |
The Queen v. Cranswick, 82 DTC 6073, [1982] CTC 69 (FCA)
The income which is typically earned by shares is dividends. A payment on shares that was of an unusual and unexpected kind, i.e., a voluntary...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 3 | 236 | |
| Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business | 103 | |
| Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement | 103 |
Ahmad v. The Queen, 2013 DTC 1112 [at 601], 2013 TCC 127 (Informal Procedure)
Before finding that a distribution in kind by a Bermudan corporation ("Tyco") was a taxable dividend to the taxpayer under s. 90, Rip CJ quoted...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 90 - Subsection 90(1) | dividend in kind on US spin-off | 115 |
Capancini v. The Queen, 2010 DTC 1394 [at 4569], 2010 TCC 581 (Informal Procedure)
Under a reorganization, the Canadian-resident taxpayer received, in exchange for shares he previously held of Tyco International Ltd. (a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 90 - Subsection 90(1) | 134 |
Cangro Resources Ltd. v. MNR, 67 DTC 582 (TAB)
A payment received by the taxpayer that was stated to be made out of "paid-in capital and paid-in surplus" pursuant to the provisions of the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | 118 | |
| Tax Topics - Income Tax Act - Section 90 - Subsection 90(1) | distributions out of share premium based on number of shares held were dividends | 231 |
Memec plc v. IRC, [1998] BTC 251, [1998] EWCA Civ 941 (CA)
In order to minimize German corporate tax payable by its German subsidiary ("GmbH"), the taxpayer "Plc"), which was a UK company, formed a silent...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 96 | German silent partnership not a partnership: purely contractual right with no participation in business | 352 |