Administrative Policy
18 July 2006 External T.I. 2005-0162181E5 F - Subsection 74.4(2)
CRA indicated that Ms. B (the common law partner of Mr. A) would be a specified shareholder of Aco (held by her and Mr. A as to 9% and 91% of the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 74.4 - Subsection 74.4(2) - Paragraph 74.4(2)(a) | a 9% spousal shareholder is a specified shareholder if she also controls a related corporation | 68 |
Paragraph (e)
Administrative Policy
26 November 2021 CTF Roundtable Q. 5, 2021-0911821C6 - Corporate Attribution
A discretionary trust whose beneficiaries included minor children owned Holdco which, in turn, held Subco. CRA indicated that each child would be...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 74.4 - Subsection 74.4(4) - Paragraph 74.4(4)(a) | s. 74.4(4)(a) exception does not apply where the indirect transfer is to a subsidiary of the trust-owned corporation | 145 |
| Tax Topics - Income Tax Act - Section 74.4 - Subsection 74.4(2) - Paragraph 74.4(2)(a) | minor beneficiaries of a discretionary trust were specified shareholders of a subsidiary of a corporation held by the trust | 146 |