Words and Phrases - "dividend"

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9 May 2002 Internal T.I. 2002-0135307 F - Application du paragraphe 39(2)

a dividend is any corporate distribution other than of PUC

Before going on to find that if a distribution made from a Delaware subsidiary’s surplus would be a dividend for ITA purposes if it was a...

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Words and Phrases
dividend
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 90 - Subsection 90(3) distribution of contributed surplus by Delaware subsidiary likely was a dividend 61
Tax Topics - Income Tax Act - Section 39 - Subsection 39(2) distribution by Delaware subsidiary that did not result in s. 40 application thereby did not engage s. 39(2) 100

Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114

Most pro rata corporate distributions are dividends (pp. 20:16-17)

Cangro Resources … held that for the purposes of the Act, “dividend” was...

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Words and Phrases
dividend
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 96 140
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(1) 127
Tax Topics - General Concepts - Ownership 283
Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(11.2) - Paragraph 5907(11.2)(b) 193
Tax Topics - Income Tax Act - Section 93.1 - Subsection 93.1(2) - Paragraph 93.1(2)(a) 128
Tax Topics - Income Tax Act - Section 93.1 - Subsection 93.1(2) - Paragraph 93.1(2)(d) - Subparagraph 93.1(2)(d)(i) 88
Tax Topics - Income Tax Regulations - Regulation 5901 - Subsection 5901(2) - Paragraph 5901(2)(b) 101
Tax Topics - Income Tax Act - Section 93 - Subsection 93(1.3) 180
Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Excluded Property - Paragraph (e) 167
Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Excluded Property - Paragraph (a) 392
Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Excluded Property - Paragraph (c) 302
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(y) 72
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph. 95(2)(z) 370
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(a) - Subparagraph 95(2)(a)(ii) - Clause 95(2)(a)(ii)(B) - Subclause 95(2)(a)(ii)(B)(II) 179
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(a) - Subparagraph 95(2)(a)(ii) - Clause 95(2)(a)(ii)(D) 712
Tax Topics - Income Tax Act - Section 94 - Subsection 94(1) - Exempt Foreign Trust - Paragraph (h) - Subparagraph (h)(ii) - Clause (h)(ii)(C) 647

Cangro Resources Ltd. v. MNR, 67 DTC 582 (TAB)

distributions out of share premium based on number of shares held were dividends

A payment received by the taxpayer that was stated to be made out of "paid-in capital and paid-in surplus" pursuant to the provisions of the...

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Words and Phrases
dividend
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) 118
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Dividend distributions out of share premium based on number of shares held were dividends 231

Ahmad v. The Queen, 2013 DTC 1112 [at at 601], 2013 TCC 127 (Informal Procedure)

Before finding that a distribution in kind by a Bermudan corporation ("Tyco") was a taxable dividend to the taxpayer under s. 90, Rip CJ quoted...

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Words and Phrases
dividend
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 90 - Subsection 90(1) dividend in kind on US spin-off 115

Memec plc v. IRC, [1998] BTC 251, [1998] EWCA Civ 941 (CA)

In order to minimize German corporate tax payable by its German subsidiary ("GmbH"), the taxpayer "Plc"), which was a UK company, formed a silent...

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Words and Phrases
dividend
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 96 German silent partnership not a partnership: purely contractual right with no participation in business 352

Guilder News Co. (1963) Ltd. v. MNR, 73 DTC 5048, [1973] CTC 1 (FCA)

At 5053:

"[M]any of the amounts that would fall under section [15(1)] would not fall within the concept of 'dividend' in its ordinary sense in...

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Words and Phrases
dividend
Locations of other summaries Wordcount
Tax Topics - General Concepts - Effective Date 229
Tax Topics - Income Tax Act - Section 121 13
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) restoration of previous year's detriment was benefit 231

The Queen v. Cranswick, 82 DTC 6073, [1982] CTC 69 (FCA)

The income which is typically earned by shares is dividends. A payment on shares that was of an unusual and unexpected kind, i.e., a voluntary...

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Words and Phrases
dividend
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a) unexpected damages payment was not income from a source 236
Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business damages received by shareholders as a windfall were not income 98
Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement 103

Capancini v. The Queen, 2010 DTC 1394 [at at 4569], 2010 TCC 581 (Informal Procedure)

Under a reorganization, the Canadian-resident taxpayer received, in exchange for shares he previously held of Tyco International Ltd. (a...

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Words and Phrases
dividend
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 90 - Subsection 90(1) 134

Cangro Resources Ltd. v. MNR, 67 DTC 582 (TAB)

distributions out of share premium based on number of shares held were dividends

A payment received by the taxpayer that was stated to be made out of "paid-in capital and paid-in surplus" pursuant to the provisions of the...

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Words and Phrases
dividend
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) 118
Tax Topics - Income Tax Act - Section 90 - Subsection 90(1) distributions out of share premium based on number of shares held were dividends 231