Principal Issues: Whether the butterfly dividends are exempt from 55(2) as a result of qualifying under 55(3)(b)?
Position: Yes.
Reasons: Proposed transactions meet the requirements of 55(3)(b).
In response to an enquiry as to the definition of “public institution” in the context of Crown corporations referred to in s. 149(1)(d), CRA...
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In response to an inquiry on the Crown corporation branch of the definition of a public institution in s. 125.7(1) of the CEWS rules, CRA first...
Principal Issues: What criteria should be considered when determining whether a particular entity is a public institution.
Position: General criteria provided.
Reasons: The determination is a question of fact.
