After finding that s. 55(2) would apply to the deemed dividend arising on the redemption of preferred shares of a CCPC held by an unrelated public...
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|Tax Topics - Income Tax Act - Section 191 - Subsection 191(4)||s. 191(4) unavailable where redemption occurred subsequently to reduction in redemption amount pursuant to a price adjustment clause||370|
|Tax Topics - Income Tax Act - Section 55 - Subsection 55(3) - Paragraph 55(3)(a) - Subparagraph 55(3)(a)(i)||s. 55(3)(a)(i) exception does not apply to a redemption of a preferred share giving rise to a deemed dividend irrespective of conversion of that dividend to capital gain||358|
|Tax Topics - Income Tax Act - Section 191.1 - Subsection 191.1(1) - Paragraph 191.1(1)(a)||dividend subject to s. 55(2) can also be subject to Pt. VI.1 tax||110|