Words and Phrases - "control"

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14 June 2010 Internal T.I. 2010-0366611I7 F - Determination of CCPC Status

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
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 251 - Subsection 251(5) - Paragraph 251(5)(b) sole beneficiary of a trust did not have a s. 251(5)(b) right to trust shares 44
Tax Topics - General Concepts - Agency application of Kinguk Trawl test of agency 165
Tax Topics - Income Tax Act - Section 256 - Subsection 256(5.1) non-resident shareholder with 60%+ economic interest, extensive veto rights and responsibility for future funding of R&D work had de facto control 457

Buckerfield's Ltd. v. MNR, 64 D.T.C 5301 (Ex Ct)

Two companies that were vigorous competitors (Pioneer and Federal) each owned one-half of the shares of two other companies (Buckerfield's and...

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Words and Phrases
control

International Iron & Metal Co. Ltd. v. Minister of National Revenue, 72 DTC 6205, [1972] CTC 242, [1974] S.C.R. 898, aff'g 69 DTC 5445, [1969] CTC 668 (Ex Ct)

A corporation ("Burland") was owned by nine children of four fathers. The taxpayer ("International Iron") would have been indirectly controlled by...

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Words and Phrases
control

Hudson's Investment Co. (London) Ltd. v. MNR, 68 DTC 83 (TAB)

An individual (Shapiro) was the shareholder of all the shares of Richard Shapiro Limited ("RSL") and of one-half of the common shares of the...

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Words and Phrases
control

Scandia Plate Ltd. v. The Queen, 83 DTC 5009, [1982] CTC 431 (FCTD)

Ownership of the shares of an alleged Canadian-controlled private corporation was not acquired by a Canadian resident from a Swedish company...

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Words and Phrases
control