Words and Phrases - "ADR"

a
82
b
44
c
75
d
50
e
37
f
31
g
17
h
13
i
71
j
2
k
2
l
30
m
51
n
25
o
38
p
79
q
2
r
74
s
85
t
44
u
14
v
8
w
20
y
2
“
1

11 May 2005 Roundtable, 2005-0118691C6 F - Certificat américain d'actions étrangères

Summary Under
Tax Topics - Income Tax Act - Section 181.2 - Subsection 181.2(4) - Paragraph 181.2(4)(a)
ADR holder holds shares if such holder has all the attributes of ownership of the shares

Does an American Depository Receipt represent shares of a corporation so that the certificate will qualify for the s. 181.2(4)(a) deduction? CRA responded:

A share is a bundle of rights and privileges accorded by the articles of incorporation or directors under the relevant legislation. It must therefore be determined whether the holder of an American Depositary Receipt has all the attributes of ownership of the shares that the certificate represents in order to deduct the amount of the investment in the American Depositary Receipt.

Words and Phrases
American Depositary Receipt ADR