Administrative Policy
14 December 2012 External T.I. 2012-0436981E5 F - Ristournes de coopératives de travailleurs
S. 149.5 of the Quebec Cooperatives Act provides for the inclusion in a shareholding workers cooperative’s enhancement reserve of a portion of...
6 October 2005 External T.I. 2005-0146061E5 F - Coop de travailleurs actionnaire - montants versés
After finding that a workers shareholder cooperative qualified as a cooperative corporation within the meaning of s. 136(2), CRA...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 82 - Subsection 82(1) - Paragraph 82(1)(a) | interest on a preferred share was a dividend | 27 |
| Tax Topics - Income Tax Act - Section 136 - Subsection 136(2) | workers shareholder cooperative qualified | 108 |
19 January 2005 External T.I. 2004-0081001E5 F - Réserve de valorisation d'une coopérative
S. 149.1 of the Quebec Cooperatives Act provided that certain cooperatives could set up an “enhancement reserve” to value the use of the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 181.2 - Subsection 181.2(3) - Paragraph 181.2(3)(b) | enhancement reserve of Quebec cooperative added to capital | 51 |
19 June 1995 Memorandum 950842 (C.T.O. "Patronage Dividends Paid by Non Co-ops")
"Although it is usually a co-operative that deducts patronage dividends, this deduction is available to any taxpayer who qualifies including sole...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Payment & Receipt | 27 |
7 June 1993 T.I. (Tax Window, No. 31, p. 23, ¶2549)
The payment by a non-profit housing project for seniors of the excess of the selling price for units over the cost of construction would not...
26 August 1992 T.I. (Tax Window, No. 23, p. 19, ¶2138)
A payor organization will not be considered to have failed to make "allocations in proportion to patronage" by virtue of members waiving their...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 135 - Subsection 135(7) | 29 |