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,...
Excluded Dividend
Articles
Joint Committee, "Summary of Feedback on Various Technical Issues", 14 April 2025 Joint Committee Submission
Inappropriateness of Pt. VI.1 tax where non-resident shareholder (p. 12)
- Where the shareholder of a taxable preferred share is a non-resident...
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...