Taxable Preferred Share

Administrative Policy

15 March 2013 External T.I. 2012-0443471E5 - Taxable Preferred Shares

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2012 Ruling 2011-0431481R3 - Short-term and Taxable Preferred Share

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7 March 2007 External T.I. 2005-0157381E5 - Regulation 6204

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2003 Ruling 2003-003407 -

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Income Tax Technical News, No. 7, 21 February 1996 (cancelled)

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25 July 1994 T.I. 940707 (C.T.O. "Taxable Preferred Shares")

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30 May 1991 T.I. (Tax Window, No. 3, p. 24, ¶1271)

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7 March 1990 T.I. (August 1990 Access Letter, ¶1392)

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18 October 89 Meeting with Quebec Accountants, Q.5 (April 90 Access Letter, ¶1166)

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Articles

Jay Lefton, Barbara Worndl, Jack Bernstein, "Exchangeable Shares", Tax Profile, Vol. 6, No. 6, June 2000, p. 61.

Ruby, "Plan of Arrangement Involving Diamond Resources Inc. and Inco Ltd", Cross-Border Taxation Issues and Developments, 1996, International Fiscal Association, p. 89

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Shafer, "Income Access Shares", 1993 Conference Report, c. 18.

Ewens, "Amending Grandfathered Preferred Share Conditions", 1994 Canadian Tax Journal, No. 42, No. 2, p. 548.

Sugg, "Preferred Share Review: Anomalies and Traps for the Unwary", 1992 Conference Report, c.22.

Woods, "Dividend Access Shares", 1991 Canadian Tax Journal, p. 709.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 206 - Paragraph 206(1)(f) 0

Ruby, "Recent Financing Techniques", 1989 Conference Report, c. 27 under "Amendments to Existing Shares -Loss of Grandfathering Status", pp. 38-40.

Ewens, "The New Preferred Share Dividend Tax Regime", 1988 Conference Report, c. 21

Paragraph (f)

Administrative Policy

5 October 2012 APFF Roundtable, 2012-0454171C6 F - Taxable Pref. Shares and Short-Term Pref. Shares

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