Words and Phrases - "ultimate control"

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29 August 2000 Internal T.I. 2000-0023187 F - Société privée sous contrôle canadien

ultimate control of Opco was held by Pubco through an indirect wholly-owned subsidiary that was the general partner of an LP holding 2/3 of Opco’s voting shares

A corporation (Opco), the voting rights of which were owned as to 1/3 by an individual and as to 2/3 by a limited partnership of which the general...

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Words and Phrases
ultimate control
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 251 - Subsection 251(2) - Paragraph 251(2)(b) - Subparagraph 251(2)(b)(i) GP generally controls a corporation whose voting control is held by a limited partnership 121

Parthenon Investments Ltd. v. Canada (National Revenue), 97 DTC 5343 (FCA)

All the voting shares of the taxpayer were owned by a Canadian corporation all of whose voting shares were owned by a U.S. corporation. All the...

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Words and Phrases
ultimate control