Words and Phrases - "holding"

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” refers to direct holding/this purpose is a question of fact

Respecting a submission that the definition of "mutual holding corporation" (the "Definition") provided for both direct and indirect holdings of shares of insurance corporations in the context of presented situations that are not repeated in the CRA letter, CRA stated:

With respect to the meaning of "holding" in the Definition, we are of the view that the legislator contemplated the direct holding and not an indirect holding of shares of the capital stock of the insurance corporation. …

However, [as] it is a question of fact whether the mutual company in the other situations [presented] was set up for the purpose of directly holding shares of an insurance corporation…we would be prepared to review all the transactions surrounding the situations you described in a request for an advance ruling.

Words and Phrases
holding
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 139.1 - Subsection 139.1(1) - Mutual Holding Corporation "holding" must be direct holding 59