Subsection 191.1(1) - Tax on taxable dividends
Administrative Policy
18 October 89 Meeting with Quebec Accountants, Q.4 (April 90 Access Letter, ¶1166)
Where a shareholder holds identical shares of a corporation some of which are taxable preferred shares and some of which were issued before 1987,...
Paragraph 191.1(1)(a)
Administrative Policy
28 January 2008 External T.I. 2007-0250831E5 F - Part IV.1 and VI.1 Taxes - Subsection 55(2)
After finding that s. 55(2) would apply to the deemed dividend arising on the redemption of preferred shares of a CCPC held by an unrelated public...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 191 - Subsection 191(4) | s. 191(4) unavailable where redemption occurred subsequently to reduction in redemption amount pursuant to a price adjustment clause | 370 |
| 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 187.2 | application of Pt. IV.1 tax to a deemed dividend is ousted to the extent s. 55(2) applies | 115 |
Subsection 191.1(2)
Articles
Austin del Rio, "Part VI.1 Tax on Dividend Paid Through Family Trust", Tax for the Owner-Manager, Vol. 19, No. 3, July 2019, p. 9
Structure for example (p. 9)
… Opco) has several shareholders. These include (1) Mr. X, who operates the business; (2) a family trust; and (3) a...