Words and Phrases - "redeem"
8 June 2000 Internal T.I. 1999-0012817 F - Sociétés associées
s. 256(6)(b) was not satisfied because control also held to protect investment in building and because shares were to be purchased for cancellation rather than redeemed
Although s. 256(6)(a) was satisfied, s. 256(6)(b) was not satisfied regarding the shareholding of Holdco1 in Opco1. Although CCRA accepted that...
Words and Phrases
redeemLocations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 256 - Subsection 256(3) | s. 256(3) does not apply where s. 256(6) does not apply | 192 |
McArdle Estate [No. 2] v. MNR, 62 DTC 402 (TAB)
repurchase and re-allotment of shares was not a redemption
The president (McArdle) of a private company had been issued “employee redeemable shares,” whose terms provided that they participated on a...
Words and Phrases
redeemLocations of other summaries | Wordcount | |
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Tax Topics - General Concepts - Substance | mistaken nomenclature ignored if inconsistent with governing intention | 66 |