Subsection 142.5(1) - Income treatment for profits and losses
Administrative Policy
11 April 2001 External T.I. 1999-0007005 - DEEMED DIVIDENDS ON MARK-TO-MARKET SHARE
The following example was provided respecting a preferred share held by a financial institution whose paid-up capital (and apparently, redemption amount) was increased:
The Agency commented that "it would have to be established that the increase in fair market value of the shares was solely the result of the increase in paid-up capital".
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) | 81 |
6 June 1997 Internal T.I. 9631867 - REDEMPTION OF SHARES HELD BY FINANCIAL INSTITUTIONS
S.142.5(1) takes precedence over s. 84(3). To the extent that an amount has been included in computing income under s. 142.5(1), such amount will not be taken into account again for purposes of s. 84(3), by virtue of s. 248(28).
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 84 - Subsection 84(3) | 38 |