Words and Phrases - "series"
12 February 2003 External T.I. 2002-0167545 - MFT - Units Issued in Series
if 2 or more series, 150-unitholder test applied by requiring the block size to be based on the unit value of the lower-value series’ units
Units of a unit trust consist of one class issued in two series, with those of the first series having a fair market value (FMV) of less than $25...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 4803 - Subsection 4803(1) - Block of Units | block size for multiple series based on FMV of least valuable unit | 102 |
| Tax Topics - Income Tax Regulations - Regulation 4801 - Paragraph 4801(a) - Subparagraph 4801(a)(i) | distribution requirement can be satisfied by only one of the series within a class | 104 |
Michael N. Kandev, John J. Lennard, "Interpreting the Expression 'Arrangement or Transaction' in the Principal Purpose Test of the MLI", International Tax (Wolters Kluwer CCH), June 2019, No. 106, p. 1
No Canadian domestic definition of the phrase “arrangement or transaction” (p.3)
While Canada’s ITA uses the words “arrangement” and...
26 May 2016 IFA Roundtable Q. 4, 2016-0642151C6 - Upstream loan converted to PLOI
the replacement of an “2nd-tier” upstream loan to a non-resident parent by a PLOI will not occur as part of the same series
Canco indirectly distributed $10M of excess cash to its non-resident parent (NRco) in 2010 through a capital contribution by it to a new foreign...
Words and Phrases
series