See Also
Terminal Dock and Warehouse Co. Ltd. v. MNR, 59 DTC 542, 23 Tax ABC 40
Whether the taxpayer was related to another corporation (“Robin Hood”) turned on whether pursuant to s. 36 of the 1948 Income Tax Act, Robin...
Administrative Policy
14 January 2020 Internal T.I. 2018-0785991I7 F - Subsection 86.1(2)
A U.S. public corporation, which had two actively-traded classes of common shares, whose respective performance tracked two businesses, wished to...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 86.1 - Subsection 86.1(2) | s. 86.1(2)(c)(i) references central management and control test/tracking shares satisfied s. 86.1(2)(a) | 185 |
11 January 2012 External T.I. 2010-0377991E5 - MIC - paragraph 130.1(6)(e)
where a corporation (intended to qualify as a mortgage investment corporation) has two classes of shares with identical attributes except that...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 130.1 - Subsection 130.1(6) | no bonus dividend entitlement | 73 |
16 September 2004 External T.I. 2004-0088521E5 - meaning of "common share"
When asked whether Class A preferred shares of a particular corporation would be common shares, the Directorate noted that in Terminal Dock and...