Words and Phrases - "de jure 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

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

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
Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 8000 - Subsection 8300(1) - Individual Pension PLan two unrelated 50% shareholders potentially could both be related to the corporation based on Duha USA rights and s. 251(5)(b) rights 295
Tax Topics - Income Tax Act - Section 251 - Subsection 251(5) - Paragraph 251(5)(b) s. 251(5)(b) deemed control does not undercut actual de jure control 161