Administrative Policy
15 March 2013 External T.I. 2012-0443471E5 - Taxable Preferred Shares
Before concluding that shares would be considered to be taxable preferred shares where they were entitled to 75% of the profit resulting from an...
2012 Ruling 2011-0431481R3 - Short-term and Taxable Preferred Share
following the approval of its shareholders for a winding-up and liquidation of a corporation, its common shares would not be taxable preferred...
7 March 2007 External T.I. 2005-0157381E5 - Regulation 6204
Although it would appear that Regulation 6204(1)(a)(i) would cause shares not to be prescribed shares if a loan agreement by the corporation...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 6204 - Subsection 6204(1) - Paragraph 6204(1)(a) | 110 |
2003 Ruling 2003-0034073 - TAXABLE PREFERRED SHARES DIVIDEND POLICY
The Class A and Class B Shares of a public corporation participated equally in such dividends as the directors determined to declare and pay in...
Income Tax Technical News, No. 7, 21 February 1996 (cancelled)
An amendment to the articles allowing a corporation to pay a stock dividend in lieu of a cash dividend on a preferred share will result in the...
24 July 1994 External T.I. 9407075 - TAXABLE PREFERRED SHARES
Where five corporate shareholders each owning 20% of the shares of a Canadian-controlled private corporation enter into an agreement of purchase...
30 May 1991 T.I. (Tax Window, No. 3, p. 24, ¶1271)
A share may be within clause (b)(i)(C) if it is entitled to a minimum preferred dividend, even if the amount of the preference is nominal and the...
7 March 1990 T.I. (August 1990 Access Letter, ¶1392)
Where a corporation issues common shares under an employee share purchase plan for an issue price lower than the shares' then fair market value...
18 October 89 Meeting with Quebec Accountants, Q.5 (April 90 Access Letter, ¶1166)
Although RC was willing to concede that it would consider not applying paragraph (e) in the case where an amendment is made to a shareholders...
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
Includes a discussion of the Inco Class VBN Shares.
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
A specified corporation in relation to the issuing corporation agrees to acquire shares for a specified amount within 60 days, but in fact the...
Articles
John O’Connor, Eryn Fanjoy, "Substantial Issuer Bids: A Tax Update", Corporate Finance, Vol. XXIV, No 1 (Federated Press), p.1, 2021
Time of agreement under substantial issuer bid (p. 5)
- In a substantial issuer bid, the agreement is not formed until the expiry of the offer, so...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 191 - Subsection 191(5) | 237 |
Subparagraph (f)(ii)
Administrative Policy
7 October 2022 APFF Roundtable Q. 2, 2022-0942091C6 F - Taxable preferred shares and shareholders’ agreement
Having regard to the exception in s. (f)(ii) of the taxable preferred share definition regarding the accommodation inter alia of a clause under...