Words and Phrases - "greater part"

a
88
b
44
c
79
d
52
e
38
f
31
g
19
h
14
i
74
j
2
k
2
l
32
m
56
n
25
o
38
p
81
q
3
r
76
s
90
t
47
u
16
v
9
w
23
y
2

8 April 2003 External T.I. 2003-000199

Summary Under
Tax Topics - Treaties - Income Tax Conventions - Article 13

After referring to Bromley v. Tryon, [1952] AC 265 (HL) ("'greater part' means anything over one-half"), CCRA stated that:

"The term 'value or the greater part of their value' as used in paragraph 5(a) of Article 13 of the [Canada-U.K.] Convention generally requires that more than 50% of the value of the shares being alienated be derived from immovable property or a right referred to in paragraph 4 of Article 13 in order for paragraph 5(a) to apply."

Words and Phrases
greater part