Section 139.1

Table of Contents

Section 139.1
Subsection 139.1(1) - Definitions
Mutual Holding Corporation
Administrative Policy(2)
Subsection 139.1(15)
Administrative Policy(1)
Subsection 139.1(16)
Administrative Policy(1)

Subsection 139.1(1) - Definitions

Mutual Holding Corporation

Administrative Policy

25 September 2014 External T.I. 2012-0451411E5 F - Mutual Holding Corporation

Respecting a submission that the definition of "mutual holding corporation" (the "Definition") provided for both direct and indirect holdings of...

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Words and Phrases
holding
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 139.1 - Subsection 139.1(1) - Mutual Holding Corporation "holding" must be direct holding 59

25 September 2014 External T.I. 2012-0451411E5 F - Mutual Holding Corporation

Does a mutual corporation qualify as a mutual holding corporation if it holds shares of the insurance corporation indirectly? After quoting from...

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Words and Phrases
hold
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 139.1 - Subsection 139.1(1) - Mutual Holding Corporation “holding” refers to direct holding/this purpose is a question of fact 137

Subsection 139.1(15)

Administrative Policy

22 May 2001 External T.I. 2000-0021095 F - DEMUTULISATION NON-RESIDENT

After discussing the application of s. 139.1(16) (where it elected) to a non-resident corporation, not carrying on business in Canada, which was...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 139.1 - Subsection 139.1(16) non-resident interest person needs to make the election for s. 139.1(16) to apply – if so, per s. 139.1(16)(k), no Part XIII tax applicable to individual re the cash payment 208

Subsection 139.1(16)

Administrative Policy

22 May 2001 External T.I. 2000-0021095 F - DEMUTULISATION NON-RESIDENT

Regarding the application of s. 139.1 to a non-resident corporation, not carrying on business in Canada, which is the policyholder of a group life...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 139.1 - Subsection 139.1(15) potential application of Pt. XIII tax to premiums paid by non-resident corporation 134

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