Administrative Policy
18 July 2006 External T.I. 2005-0162181E5 F - Subsection 74.4(2)
9% shareholder of corporation otherwise held by her spouse becomes a specified shareholder if she wholly-owns a second corporation
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 common shares, respectively) if she also wholly-owned Bco (a related corporation to Aco).
Locations of other summaries | Wordcount | |
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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
beneficiaries of a discretionary trust were specified shareholders of a grandchild trust subsidiary
A discretionary trust whose beneficiaries included minor children owned Holdco which, in turn, held Subco. CRA indicated that each child would be deemed under para. (e) of the specified shareholder definition to wholly own Holdco, so that each child also would be a specified shareholder, under that definition, of the related corporation (Subco).
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 |