Dividend

Table of Contents

Cases

Delage v. Canada, 2002 DTC 7061, 2002 FCA 212

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Dale v. Canada, 97 DTC 5252 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - General Concepts - Effective Date retroactive superior court order has retroactive effect for tax purposes 162
Tax Topics - General Concepts - Rectification & Rescission retroactive effect of nunc pro tunc rectification order 167
Tax Topics - Income Tax Act - Section 83 - Subsection 83(2) 76
Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) retroactive validation by Superior Court of preference share issuance was effective for s. 85 purposes 165
Tax Topics - Statutory Interpretation - Provincial Law 134

M.S.S. Inc. v. The Queen, 87 DTC 5088, [1987] 1 CTC 130 (FCTD), aff'd 89 DTC 5502 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

The Queen v. Cranswick, 82 DTC 6073, [1982] CTC 69 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
dividend

Bernstein v. MNR, 74 DTC 6041, [1974] CTC 4 (FCTD), aff'd 77 DTC 5187, [1977] CTC 328 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) no reorganization of corporation 68

Guilder News Co. (1963) Ltd. v. MNR, 73 DTC 5048, [1973] CTC 1 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
dividend
Locations of other summaries Wordcount
Tax Topics - General Concepts - Effective Date 223
Tax Topics - Income Tax Act - Section 121 11
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) restoration of previous year's detriment was benefit 225

Gabco Ltd. v. MNR, 68 DTC 5210, [1968] CTC 313 (Ex Ct)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 67 "unreasonable" if no reasonable business would have paid it 190

See Also

Ahmad v. The Queen, 2013 DTC 1112 [at 601], 2013 TCC 127 (Informal Procedure)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
dividend
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 90 - Subsection 90(1) dividend in kind on US spin-off 107

Marshall v. The Queen, 2011 DTC 1353 [at 1976], 2011 TCC 497

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 90 - Subsection 90(1) 113

Capancini v. The Queen, 2010 DTC 1394 [at 4569], 2010 TCC 581 (Informal Procedure)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
dividend
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 90 - Subsection 90(1) 132

Mulligan v. The Queen, 99 DTC 951 (TCC) (Informal Procedure)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Memec plc v. IRC, [1998] BTC 251, [1998] EWCA Civ 941 (CA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
dividend
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 96 German silent partnership not a partnership: purely contractual right with no participation in business 340

Canadian Pacific Ltd. (1990), 72 OR (2d) 545 (Ont HCJ.)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Anderson v. The Queen, 98 DTC 1027 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Daggett v. MNR, 93 DTC 14 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) 81

Re Telsten Services Ltd. (1981), 39 C.B.R. (N.S.) 68 (S.C.O.)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Canadian Pacific Ltd. (1990), 72 OR (2d) 545 (Ont HCJ.)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Cangro Resources Ltd. v. MNR, 67 DTC 582 (TAB)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
dividend
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) 110
Tax Topics - Income Tax Act - Section 90 - Subsection 90(1) distributions out of share premium based on number of shares held were dividends 211

Administrative Policy

11 April 2017 Internal T.I. 2016-0670541I7 - Foreign affiliate share redemption

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 90 - Subsection 90(2) portion of proceeds paid on a redemption might be respected as a dividend (subject to s. 95(6)) if this is clearly indicated in accordance with Barbados law 289
Tax Topics - Income Tax Act - Section 95 - Subsection 95(6) - Paragraph 95(6)(b) skewing exempt surplus to Canco could engage s. 95(6) 126

25 August 2014 External T.I. 2014-0528361E5 - premium on redemption of foreign affiliate shares

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 90 - Subsection 90(1) redemption premium is proceeds 68

30 April 2013 Internal T.I. 2012-0439741I7 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Share treatment of MRPS as equity 180
Tax Topics - Income Tax Act - Section 90 - Subsection 90(1) treatment of MRPS as equity 199

8 April 2004 Internal T.I. 2003-0037291I7 - US LLC and Regulation 5907(1.3)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

16 April 2012 External T.I. 2011-041149 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) 246(1) application to payment of individual's US taxes by grandchild LLC 110

22 January 1997 T.I. 970129 (C.T.O. "Dividend in Kind - U.S. Divestiture")

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

8 January 1996 T.I. 942802 (C.T.O. "Return of Capital from a Delaware Corporation")

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions - Article 10 104

16 May 1994 T.I. 940456 (C.T.O. "Court Ordered Corporate Distribution")

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) 106

5 September 89 T.I. (February 1990 Access Letter, ¶1101)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

IT-67R3 "Taxable Dividends from Corporations Resident in Canada"

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Articles

John R. Owen, "Foreign Entity Classification and the Character of Foreign Distributions", 2005 Conference Report, c. 20

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Wertschek, "The Tax Advisor and Commercial Law: Some Issues", 1993 Conference Report, C. 24

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Navigation