Subsection 130.1(6)
Administrative Policy
20 March 2015 External T.I. 2014-0528311E5 - Mortgage Investment Corporation - RRSP
Would shareholdings of a specified shareholder include those of a brother or sister? CRA stated:
[R]elated persons for purposes of subparagraph...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(4) - Paragraph 207.01(4)(a) | shareholdings of siblings | 111 |
2013 Ruling 2013-0487911R3 - Mortgage Investment Corporation
underline;">: Background. Opco, which qualifies as a MIC under s. 130.1(6), acquired real property (the Property) on foreclosing on a mortgage. ...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 253.1 | carrying on non-qualifying activities through subsidiary LP; GP held by relative of patriarch | 206 |
12 October 2012 External T.I. 2012-0450291E5 - Mortgage Investment Corporation investing
In response to a question as to whether a mortgage investment corporation ("MIC") will satisfy the requirements in s. 130.1(6)(b) that its only...
29 March 2012 External T.I. 2011-0415641E5 - Mortgage Investment Corporation
After noting that s. 253.1 applied only for the purposes of s. 130.1(6)(b) rather than the other provisions of s. 130.1(6)(b), CRA noted that "the...
29 March 2012 External T.I. 2011-0403161E5 - Meaning of "shareholder" in 130.1(6)(d)
For the purposes of the 20-shareholder test in s. 130.1(6)(d), an individual and the individual's RRSP and TFSA trusts would each count as a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 4801 - Paragraph 4801(a) | RRSP is separate unitholder | 32 |
11 January 2012 External T.I. 2010-0377991E5 - MIC - paragraph 130.1(6)(e)
Where a corporation (intended to qualify as a mortgage investment corporation) has two classes of shares with identical attributes except that...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Common Share | 73 |
4 December 1997 External T.I. 9726425 - MIC'S AND REAL ESTATE
"Where a corporation otherwise would have met all the conditions outlined in subsection 130.1(6) of the Act acquires real property either for...
23 January 1992 T.I. (Tax Window, No. 16, p. 16, ¶1711)
A corporation the common shares of which are held by one shareholder and the preferred shares of which are held by 19 shareholders potentially...
14 January 1992 T.I. (Tax Window, No. 15, p. 19, ¶1697)
Investments in the shares of a mutual fund corporation investing in mortgages would not qualify as a type of property listed in s. 130.1(6)(f)(i).
5 March 1991 T.I. (Tax Window, No. 2, p. 25, ¶1180)
A mortgage investment corporation will not necessarily lose its status as such by entering into an advisory management services agreement with an...
18 December 1990 T.I. (Tax Window, Prelim. No. 2, p. 20, ¶1061)
Retirement and nursing homes qualify as residential property.
Articles
Spindler, "Special-Status Entities", 1989 Conference Report, c. 23, pp. 23:1-23:9
Paragraph 130.1(6)(d)
Administrative Policy
12 August 2020 External T.I. 2019-0833841E5 - MIC Shareholder Count - Joint holders
How would the 20-shareholder and 25% tests in s. 130.1(6)(d) be applied where a husband and wife hold a share as joint tenants (with rights of...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 4801 - Paragraph 4801(b) | joint tenants potentially treated as single security holder | 119 |
26 October 2015 External T.I. 2015-0599021E5 - Establishment of a MIC
A parent trading on a Canadian stock exchange wholly-ownd several corporations, one of which is targeted to satisfy the MIC tests subject to...
Paragraph 130.1(6)(f)
Administrative Policy
12 January 2018 External T.I. 2016-0669431E5 - Mortgage Investment Corporation Definition
In answering a question which it treated as being directed at the scope of s. 130.1(6)(f), CRA referred to the definitions in the NHA of...