Administrative Policy
8 January 2016 Internal T.I. 2015-0604491I7 - mandatory redeemable preferred shares
Canadian Parent holds mandatorily redeemable preferred shares (“MRPS”), as well as ordinary common shares in private limited liability...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 90 - Subsection 90(2) | distributions on MRPS were equity distributions | 117 |
18 June 2015 STEP Roundtable Q. 3, 2015-0572201C6 - 2015 STEP Q3 Redeemable Preferred Shares and 18(4)
Does the position in 9619120 still apply? CRA responded:
It continues to be the position of the CRA that the classification of a financial...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(5) - Equity Amount - Paragraph (a) | equity/debt classification based on legal form | 57 |
2 February 2015 External T.I. 2013-0510751E5 F - Cooperatives and Dividend Refund
In finding that a cooperative formed under the Quebec Cooperatives Act that is neither an agricultural cooperative corporation nor a cooperative...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 129 - Subsection 129(1) | entitlement of agricultural cooperative corporations or cooperative corporations to dividend refunds | 239 |
30 April 2013 Internal T.I. 2012-0439741I7
withdrawn by CRA on 25 August 2014
Mandatory Redeemable Preferred Shares ("MRPS"): are voting; have a mandatory redemption date approximately 10...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Dividend | treatment of MRPS as equity | 198 |
| Tax Topics - Income Tax Act - Section 90 - Subsection 90(1) | treatment of MRPS as equity | 211 |
2012 Ruling 2012-0452291R3 - XXXXXXXXXX - ATR
A Canadian public company (Pubco) (acting through a branch in Country 1 – assumed here to be Luxembourg) will subscribe with cash for common...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 17 - Subsection 17(2) | 571 | |
| Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(2) | 589 |
15 July 2011 Internal T.I. 2010-0388621I7 - Entity Classification - Liechtenstein Anstalt
CRA referred to the finding in Ryall v. Du Bois that in substance a share represented "a portion of the capital" of a company and further stated...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation | anstalt a corp | 98 |
| Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Foreign Affiliate | 140 |
2010 Ruling 2009-0347271R3 - Foreign Affiliate Restructuring Financing
In accordance with its constating document, a foreign cooperative (Forco1) has the following general characteristics:
(a) Forco1 is a legal entity...
2010 Ruling 2010-0373801R3 - Conversion from a BV to a DC
Proposed transactions
BV, which is a private limited liability company under Dutch law, will convert into a Dutch cooperative ("DC") pursuant to...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 85.1 - Subsection 85.1(3) | drop-down by the two Cdn. “shareholders” of Dutch co-op (DC) of FAs in consideration for proportionate “increases” in their membership interests considered to be for “shares” | 199 |
| Tax Topics - Income Tax Act - Section 95 - Subsection 95(4) - Direct Equity Percentage | 46 | |
| Tax Topics - Income Tax Act - Section 86 - Subsection 86(1) | exchange of shares in Netherlands BV for membership interests in Dutch coop qualified under s. 86 | 147 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | conversion of Netherlands BV to Dutch co-op | 97 |
9 June 2005 External T.I. 2004-0092001E5 F - Droits indivis dans les actions
As the result of the winding up of a partnership that held shares of a small business corporation, one of the former partners has held undivided...
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|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Qualified Small Business Corporation Share | undivided interests in SBC shares on s. 98(3) winding up could qualify as shares of QSBC shares | 186 |
21 June 2001 External T.I. 2001-0086285 F - Disposition transitoire à 112(3)
CCRA indicated that the condition in 1995 transitional provisions for s. 112(3) and (3.2) regarding the financing through life insurance proceeds...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 112 - Subsection 112(3) | condition in 1995 transitional provision for the financing of the redemption of a preferred share includes part of a share | 242 |
| Tax Topics - General Concepts - Transitional Provisions and Policies | transitional provision re “share” to be applied on a share-by-share basis | 29 |
IT-392 (Archived) "Meaning of the Term 'Share'"
3. In those instances in which the ownership of a foreign business entity is not divided into units entitled "shares", and in which the foreign...