Words and Phrases - "de jure control"

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

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

11 May 2017 Internal T.I. 2016-0665931I7 - Related to participating employer

Summary Under
Tax Topics - Income Tax Act - Section 251 - Subsection 251(2) - Paragraph 251(2)(b) - Subparagraph 251(2)(b)(i)
under Duha, a 50% shareholder potentially can have de jure control

Respecting where two unrelated individuals each held exactly 50% of the (voting common) shares of their employer corporation, the Directorate...

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Words and Phrases
de jure control