Income Tax Technical News, No. 41, 23 December 2009 Under "Definition of 'Tax Shelter' - Subsection 237.1(1)

"The Maege Decisions ... do not represent a departure from the requirement that statements or representations be made in connection with the...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

"Eligible Dividend Designation - Subsection 89(14)": A taxable dividend, designated as an eligible dividend under s. 89(14) that is paid to a...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Under the "more than five full-time employees test", CRA accepts that the test is met when a corporation has five full-time employees plus one or...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

"Meaning of Business": Discussion of determination as to whether gambling is a business.

Where the full amount of the dividend paid by a CCPC is designated as an eligible dividend but a portion of the dividend is received by a...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

"Eligible Dividend Designation - Subsection 89(14)".

If a particular premium on a convertible debt obligation represented participating debt interest, all interest on the obligation would be...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

The amount considered to be repaid on the conversion of a convertible debenture generally will be the stated capital of the shares issued.

If a...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Assume that USco carries on an active business in the United States (other than an investment business). USco owns all of the shares of Canco, a...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

"The sole fact that the fair market value of the shares issued on conversion exceeds the issue price of the convertible debt obligation is not,...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.