de jure control

Summary Under
Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Canadian-Controlled Private Corporation - Paragraph (b)
agreement was not a USA since it did not contain an outright transfer of the powers of the directors to the shareholders

At issue was whether a start-up Canadian private corporation engaged in SR&ED was a Canadian-controlled private corporation (“CCPC”). ...

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Words and Phrases
de jure control control
Summary Under
Tax Topics - Income Tax Act - Section 251 - Subsection 251(2) - Paragraph 251(2)(b) - Subparagraph 251(2)(b)(i)
under Duha, a 50% shareholder potentially can have de jure control

Respecting where two unrelated individuals each held exactly 50% of the (voting common) shares of their employer corporation, the Directorate...

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Words and Phrases
de jure control
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