Words and Phrases - "derived directly or indirectly"
10 January 2020 External T.I. 2019-0819431E5 - TOSI
"derived directly or indirectly" to be construed broadly
A professional corporation (PC1), whose voting shares have been held by Dr. A (a physician) and whose non-voting participating shares have been...
Words and Phrases
derived directly or indirectlyLocations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 120.4 - Subsection 120.4(1) - Related Business | business was related business even if dividends paid after business’ discontinuance | 441 |
Tax Topics - Income Tax Act - Section 120.4 - Subsection 120.4(1) - Excluded Shares - Paragraph (c) | GAAR could be applied where excluded share status is achieved through shifting a professional services business | 533 |