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Table of Contents

Administrative Policy

8 January 2016 Internal T.I. 2015-0604491I7 - mandatory redeemable preferred shares

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Words and Phrases
share
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 90 - Subsection 90(2) distributions on MRPS were equity distributions 111

18 June 2015 STEP Roundtable Q. 3, 2015-0572201C6 - 2015 STEP Q3 Redeemable Preferred Shares and 18(4)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(5) - Equity Amount - Paragraph (a) equity/debt classification based on legal form 51

2 February 2015 External T.I. 2013-0510751E5 F - Cooperatives and Dividend Refund

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 129 - Subsection 129(1) entitlement of agricultural cooperative corporations or cooperative corporations to dividend refunds 225

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

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Dividend treatment of MRPS as equity 194
Tax Topics - Income Tax Act - Section 90 - Subsection 90(1) treatment of MRPS as equity 199

2012 Ruling 2012-0452291R3 - XXXXXXXXXX - ATR

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15 July 2011 Internal T.I. 2010-0388621I7 - Entity Classification - Liechtenstein Anstalt

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2010 Ruling 2009-0347271R3 - Foreign Affiliate Restructuring Financing

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2010 Ruling 2010-0373801R3 - Conversion from a BV to a DC

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 85.1 - Subsection 85.1(3) 44
Tax Topics - Income Tax Act - Section 95 - Subsection 95(4) - Direct Equity Percentage 44
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. 86 139
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition conversion of Netherlands BV to Dutch co-op 89

IT-392 (Archived) "Meaning of the Term 'Share'"

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Articles

Sheppard, "U.S. Treasury Department Stands up to Wall Street with Notices on Equity-Flavored Debt and Ruling on Intercorporate Dividends", Tax Notes International, May 2, 1994, p. 1182.

Edgar, "The Classification of Corporate Securities for Income Tax Purposes", 1990 Canadian Tax Journal, p. 1141.

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