Words and Phrases - "significant"
17 November 2015 Roundtable, 2015-0613821C6 - TEI question on section 55
regular dividends not in excess of return on comparable listed shares not included/ "significant" measured in dollar or %
TEI members remain concerned that, because all dividends result in a reduction of the fair-market value of shares held by the dividend payor and...
Words and Phrases
significant3 December 2015 External T.I. 2015-0593941E5 F - Allocation of the safe income on hand
quaere whether 7% reduction is significant/ $50,000 is significant in absolute terms
CRA declined to express a view as to whether an $8,000 reduction in an accrued capital gain of $120,000 was significant. A $50,000 dividend...
Words and Phrases
significant| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) | flexible allocation of SIOH where discretionary common shares | 1317 |
| Tax Topics - General Concepts - Fair Market Value - Shares | FMV of discretionary share increased at moment of dividend declaration to exclusion of other discretionary shares | 94 |
2 June 2015 Ruling 169081
Summary Under
Tax Topics - Excise Tax Act - Schedules - Schedule V - Part VI - Section 17 - Paragraph 17(e)“insignificant” is less than 30%
The “Organization,” which is a "municipality" under para. (b) of “municipality” in s. 123(1) and, therefore, a "public sector body,"...
Words and Phrases
significant3 November 1997 External T.I. 9725615 - INCREASE IN INTEREST
meaning of "significant"
"In circumstances where no person has acquired any shares of the corporation in question, it is our view that for the purposes of determining...
Words and Phrases
significantCanada v. VIH Logging Ltd., 2005 DTC 5095, 2005 FCA 36
stub income included in SIOH/ $45K out of $1.7M not significant
Cash dividends paid by a corporation ("Old VIH") to its parent (the taxpayer) in February 1993 came out of safe income of Old VIH given that the...