Administrative Policy
28 June 2001 External T.I. 2001-0073205 - SUBSTANTIAL ISSUER BID
Where a corporation proceeds with a substantial issuer bid at a price that is at a premium over the previous trading price of its shares on a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Fair Market Value - Shares | 118 |
4 October 2000 External T.I. 2000-0039205 - SPECIAL LIQUIDATION RIGHT TERM PREF. SHARES
"Generally, where a shareholder is entitled to have a share redeemed in the event of a sale or merger at any time of the underlying corporation,...
93 C.R. - Q. 10
A share is considered to be "convertible" or "exchangeable" for purposes of paragraph (b) where either the holder or the issuing corporation has...
2 November 89 T.I. (April 90 Access Letter, ¶1191)
An ESOP or an EVCP must require that the corporation redeem a shareholder's shares in certain circumstances for an amount determined in accordance...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) | 43 | |
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | 50 |
Articles
Sugg, "Preferred Share Review: Anomalies and Traps for the Unwary", 1992 Conference Report, c.22.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Dividend Rental Agreement | 0 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxable Preferred Share | 0 |
Paragraph (a)
Subparagraph (a)(i)
Administrative Policy
2024 Ruling 2023-0970691R3 F - Part VI.1 of the Income Tax Act
Background
A CCPC (B Ltd.) has two outstanding classes of common shares: the Class B common shares are held by three taxable Canadian corporations...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxable Preferred Share - Paragraph (f) | TPS definition did not apply to common share repurchase agreement where repurchase price in fact did not exceed FMV at closing time | 390 |
30 March 2010 Internal T.I. 2010-0354391I7 F - P.VI.1:Rachat à l'enchère hollandaise modifiée
A Canadian public corporation (the “Corporation") purchased for cancellation common shares that were tendered to it under an issuer bid under...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Fair Market Value - Shares | purchase price established under modified Dutch auction represented the tendered shares’ FMV | 74 |