Words and Phrases - "share"
29 May 2001 Internal T.I. 2000-0053257 F - COOPERATIVE
shares need not be fully paid
The Directorate indicated that shares for purposes of s. 136(2)(d) would include shares that had been subscribed for by the member but not fully...
Words and Phrases
share9 June 2005 External T.I. 2004-0092001E5 F - Droits indivis dans les actions
Summary Under
Tax Topics - Income Tax Act - Section 110.6 - Subsection 110.6(1) - Qualified Small Business Corporation Shareundivided interests in SBC shares on s. 98(3) winding up could qualify as shares of QSBC shares
As the result of the winding up of a partnership that held shares of a small business corporation, one of the former partners has held undivided...
Words and Phrases
share22 November 2012 External T.I. 2012-0441781E5 F - Prohibited Investment - Cooperative
investor in cooperative holds shares and is shareholder
Before concluding that “for the purposes of the Act, a cooperative is a corporation, a share of the capital stock of a cooperative is a share...
8 January 2016 Internal T.I. 2015-0604491I7 - mandatory redeemable preferred shares
MRPS (Luxembourg hybrid instruments which were “very similar to traditional shares under Canadian business corporations statutes”) were equity
Canadian Parent holds mandatorily redeemable preferred shares (“MRPS”), as well as ordinary common shares in private limited liability...
Words and Phrases
share