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) 165
Tax Topics - Income Tax Act - Section 249 - Subsection 249(4) voting rights shifted to 2nd trust with same trustees: no control change 169
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 177

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 54

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

1996 Ruling 3-960956 -

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