Words and Phrases - "control"

a
88
b
44
c
81
d
55
e
38
f
31
g
20
h
15
i
75
j
2
k
2
l
32
m
57
n
25
o
38
p
81
q
3
r
77
s
91
t
47
u
16
v
10
w
23
y
2

14 June 2010 Internal T.I. 2010-0366611I7 F - Determination of CCPC Status

Summary Under
Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Canadian-Controlled Private Corporation - Paragraph (b)
agreement was not a USA since it did not contain an outright transfer of the powers of the directors to the shareholders

At issue was whether a start-up Canadian private corporation engaged in SR&ED was a Canadian-controlled private corporation (“CCPC”). ...

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Words and Phrases
de jure control control
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 251 - Subsection 251(5) - Paragraph 251(5)(b) sole beneficiary of a trust did not have a s. 251(5)(b) right to trust shares 44
Tax Topics - General Concepts - Agency application of Kinguk Trawl test of agency 165
Tax Topics - Income Tax Act - Section 256 - Subsection 256(5.1) non-resident shareholder with 60%+ economic interest, extensive veto rights and responsibility for future funding of R&D work had de facto control 457

International Iron & Metal Co. Ltd. v. Minister of National Revenue, 72 DTC 6205, [1972] CTC 242, [1974] S.C.R. 898, aff'g 69 DTC 5445, [1969] CTC 668 (Ex Ct)

Summary Under
Tax Topics - Income Tax Act - Section 256 - Subsection 256(1) - Paragraph 256(1)(b)
ignore voting agreements

A corporation ("Burland") was owned by nine children of four fathers. The taxpayer ("International Iron") would have been indirectly controlled by...

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Words and Phrases
control

Buckerfield's Ltd. v. MNR, 64 D.T.C 5301, [1964] CTC 504 (Ex Ct)

Summary Under
Tax Topics - Income Tax Act - Section 256 - Subsection 256(1) - Paragraph 256(1)(b)
control referable to board election votes

Two companies that were vigorous competitors (Pioneer and Federal) each owned one-half of the shares of two other companies (Buckerfield's and...

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Words and Phrases
control

Plomberie J.C. Langlois Inc. c. La Reine, 2006 DTC 2997, 2004 TCC 734, aff'd supra.

Summary Under
Tax Topics - Income Tax Act - Section 256 - Subsection 256(5.1)
sole director who had a 50% shareholding had de facto control

The taxpayer and its 50% corporate shareholder were found to be subject to the de facto control of the same person (an individual who was the sole...

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Words and Phrases
control

Hudson's Investment Co. (London) Ltd. v. MNR, 68 DTC 83 (TAB)

Summary Under
Tax Topics - Income Tax Act - Section 251 - Subsection 251(5) - Paragraph 251(5)(b)

An individual (Shapiro) was the shareholder of all the shares of Richard Shapiro Limited ("RSL") and of one-half of the common shares of the...

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Words and Phrases
control

Scandia Plate Ltd. v. The Queen, 83 DTC 5009, [1982] CTC 431 (FCTD)

Summary Under
Tax Topics - Income Tax Act - Section 125 - Subsection 125(1)

Ownership of the shares of an alleged Canadian-controlled private corporation was not acquired by a Canadian resident from a Swedish company...

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Words and Phrases
control