Words and Phrases - "share"
9 June 2005 External T.I. 2004-0092001E5 F - Droits indivis dans les actions
undivided interests in SBC shares on s. 98(3) winding up could qualify as shares of QSBC shares
As the result of the winding up of a partnership that held shares of a small business corporation, one of the former partners has held undivided...
Words and Phrases
shareLocations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Share | undivided interests in QSBC shares qualify as shares | 97 |
22 November 2012 External T.I. 2012-0441781E5 F - Prohibited Investment - Cooperative
investor in cooperative holds shares and is shareholder
Before concluding that “for the purposes of the Act, a cooperative is a corporation, a share of the capital stock of a cooperative is a share...
Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(15) | application to shares of cooperative | 115 |
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(1) - Prohibited Investment - Paragraph (b) - Subparagraph (b)(i) | share of cooperative can be a share of corporation for prohibited investment purposes | 71 |
8 January 2016 Internal T.I. 2015-0604491I7 - mandatory redeemable preferred shares
MRPS (Luxembourg hybrid instruments which were “very similar to traditional shares under Canadian business corporations statutes”) were equity
Canadian Parent holds mandatorily redeemable preferred shares (“MRPS”), as well as ordinary common shares in private limited liability...
Words and Phrases
shareLocations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 90 - Subsection 90(2) | distributions on MRPS were equity distributions | 117 |