Words and Phrases - "hold"

a
86
b
44
c
76
d
50
e
38
f
31
g
18
h
14
i
73
j
2
k
2
l
32
m
56
n
25
o
38
p
80
q
3
r
76
s
89
t
46
u
15
v
9
w
23
y
2

25 September 2014 External T.I. 2012-0451411E5 F - Mutual Holding Corporation

Summary Under
Tax Topics - Income Tax Act - Section 139.1 - Subsection 139.1(1) - Mutual Holding Corporation
"holding" must be direct holding

Does a mutual corporation qualify as a mutual holding corporation if it holds shares of the insurance corporation indirectly? After quoting from the mutual holding corporation definition, CRA stated (TaxInterpretations translation):

[T]he legislator contemplated the direct holding and not an indirect holding of shares of the capital stock of the insurance corporation.

Words and Phrases
hold
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 139.1 - Subsection 139.1(1) - Mutual Holding Corporation “holding” refers to direct holding/this purpose is a question of fact 137