Words and Phrases - "share"

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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...

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Words and Phrases
share
Locations of other summaries Wordcount
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...

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Words and Phrases
share shareholder
Locations of other summaries Wordcount
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...

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Words and Phrases
share
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 90 - Subsection 90(2) distributions on MRPS were equity distributions 117