Section 191

Subsection 191(1) - Definitions

Private Holding Corporation

Administrative Policy

3 March 1992 T.I. (Tax Window, No. 17, p. 22, ¶1776)

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Subsection 191(2) - Substantial interest

Administrative Policy

91 C.R. - Q.7

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Ownership 14

88 C.R. - Q.38

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Subsection 191(3) - Idem [Substantial interest]

Administrative Policy

18 December 2013 External T.I. 2013-0511101E5 F - Substantial interest - Part VI.1

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition no disposition of shares that became voting by operation of law (due to cancellation of voting shares) 171
Tax Topics - Income Tax Act - Section 249 - Subsection 249(4) voting rights shifted to 2nd trust with same trustees: no control change 179
Tax Topics - Income Tax Act - Section 251.2 - Subsection 251.2(2) - Paragraph 251.2(2)(a) no acquisition of control where votes pass from trust to an estate with the same individuals as executors 187

Subsection 191(4) - Deemed dividends

See Also

Dangerfield v. Canada, 2004 DTC 6025, 2003 FCA 480

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Henderson Estate v. M.N.R, 73 DTC 5471, [1973] CTC 636 (FCTD), aff'd 75 D.TC 5332, [1975] C.TC 485 (FCA)

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Administrative Policy

4 May 2016 External T.I. 2016-0634551E5 - Ss 191(4) and PAC

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Price Adjustment Clause effectiveness of share price adjustment clause on previously redeemed preferred shares can trigger Part VI.1 tax 56

28 January 2008 External T.I. 2007-0250831E5 F - Part IV.1 and VI.1 Taxes - Subsection 55(2)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 55 - Subsection 55(3) - Paragraph 55(3)(a) - Subparagraph 55(3)(a)(i) s. 55(3)(a)(i) exception does not apply to a redemption of a preferred share giving rise to a deemed dividend irrespective of conversion of that dividend to capital gain 358
Tax Topics - Income Tax Act - Section 191.1 - Subsection 191.1(1) - Paragraph 191.1(1)(a) dividend subject to s. 55(2) can also be subject to Pt. VI.1 tax 110
Tax Topics - Income Tax Act - Section 187.2 application of Pt. IV.1 tax to a deemed dividend is ousted to the extent s. 55(2) applies 115

25 September 1991 Memorandum (Tax Window, No. 10, p. 5, ¶1480)

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15 May 1990 T.I. (October 1990 Access Letter, ¶1483)

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May 1990 Vancouver District Office Round Table (October 1990 Access Letter, ¶1445)

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May 1990 Meeting of Toronto Chapter of I.C.A.O. (October 1990 Access Letter, ¶1445)

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89 C.R. - Q.20

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88 C.R. - Q.37

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Articles

Charles P. Marquette, "Hybrid Sale of Shares and Assets of a Business", Canadian Tax Journal, (2014) 62:3, 857 – 79.

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 84 - Subsection 84(2) 520

Subsection 191(5) - Where s. (4) does not apply

Administrative Policy

30 November 1995 Ruling 9609563 - SHORT-TERM PREFERRED SHARES AND TAXABLE PREFERRED SHARES

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