Term Preferred Share

Cases

Canada v. Citibank Canada, 2002 DTC 6876, 2002 FCA 128

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Ordinary Meaning 144

See Also

MacNiven v. Westmoreland Investments Ltd., [2001] 1 All ER 865 (HL)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Payment & Receipt interest paid with loan 124
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(d) capitalization of interest through payment and readvance respected 124
Tax Topics - Statutory Interpretation - Ordinary Meaning 62

Penner v. The Queen, 94 DTC 6567 (FCTD)

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Apple Fields Ltd. v. New Zealand Apple and Pear Marketing Board, [1991] 2 WLR 129 (PC)

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Words and Phrases
arrangement

Administrative Policy

1999 Ruling 992747

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11 September 1996 Internal T.I. 7-961310 -

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1996 Tax Ruling 961084 (C.T.O. "Conversion of Debt into Preferred Shares")

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14 September 1994 T.I. 941992 (C.T.O. "Section 84(4.2)")

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93 C.R. - Q. 9

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17 July 1992 External T.I. 5-911644 -

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26 June 1992 T.I. 911683 (March 1993 Access Letter, p. 87, ¶C248-128)

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91 C.R. - Q.15

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23 September 1991 T.I. (Tax Window, No. 9, p. 19, ¶1468)

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16 October 1990 T.I. (Tax Window, Prelim. No. 1, p. 22, ¶1027)

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89 C.R. - Q.19

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89 C.R. - Q.17

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89 C.R. - Q.18

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ATR-5 (16 Dec. 85)

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84 C.R. - Q.61

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ATR-46, February 21, 1992

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Articles

Elinore J. Richardson, "Term Preferred Shares Revisited", Corporate Finance, Vol VIII, No. 2, 2000, p. 726

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Skingle, "A Guide through the Preferred Share Maze", 1994 Canadian Petroleum Tax Journal, Vol. 7, No. 1, p. 79.

Darling, "Revenue Canada Perspectives", 1992 Corporate Management Tax Conference Report, c. 5.

Schafer, "Tax Implications of Restructuring and Refinancing", under "Distress Preferred Shares", 1992 Corporate Management Tax Conference Report, c. 4.

Worndl, "Debt Restructuring for a Corporation in Financial Difficulty", Tax Profile, February, 1991

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Brussa, "Strategies for Troubled Times", 1990 Conference Report, c. 9

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Ruby, "Recent Financing Techniques", 1989 Conference Report, c.27 under "Perpetual Preferred Shares"

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Dyer, "Preferred Share Financing", 1986 Corporate Management Tax Conference, p. 20.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 112 - Subsection 112(2.2) 10

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