![]() (5) For the purposes of subsection 251(2) and the definition Canadian-controlled private corporation in subsection 125(7), Marginal note:Control by related groups, options, etc. Unrelated group means a group of persons that is not a related group. ( groupe non lié) Related group means a group of persons each member of which is related to every other member of the group ( groupe lié) unrelated group Marginal note:Definitions concerning groups (3.2) Where there has been an amalgamation or merger of 2 or more corporations each of which was related (otherwise than because of a right referred to in paragraph 251(5)(b)) to each other immediately before the amalgamation or merger, the new corporation formed as a result of the amalgamation or merger and each of the predecessor corporations is deemed to have been related to each other. Marginal note:Amalgamation of related corporations (3.1) Where there has been an amalgamation or merger of two or more corporations and the new corporation formed as a result of the amalgamation or merger and any predecessor corporation would have been related immediately before the amalgamation or merger if the new corporation were in existence at that time, and if the persons who were the shareholders of the new corporation immediately after the amalgamation or merger were the shareholders of the new corporation at that time, the new corporation and any such predecessor corporation shall be deemed to have been related persons. Marginal note:Relation where amalgamation or merger (3) Where two corporations are related to the same corporation within the meaning of subsection 251(2), they shall, for the purposes of subsections 251(1) and 251(2), be deemed to be related to each other. Marginal note:Corporations related through a third corporation (vi) if each member of an unrelated group that controls one of the corporations is related to at least one member of an unrelated group that controls the other corporation. (v) if any member of a related group that controls one of the corporations is related to each member of an unrelated group that controls the other corporation, or (iv) if one of the corporations is controlled by one person and that person is related to each member of an unrelated group that controls the other corporation, (iii) if one of the corporations is controlled by one person and that person is related to any member of a related group that controls the other corporation, (ii) if each of the corporations is controlled by one person and the person who controls one of the corporations is related to the person who controls the other corporation, (i) if they are controlled by the same person or group of persons, (iii) any person related to a person described in subparagraph 251(2)(b)(i) or 251(2)(b)(ii) and ![]() (ii) a person who is a member of a related group that controls the corporation, or (i) a person who controls the corporation, if it is controlled by one person, ![]() (a) individuals connected by blood relationship, marriage or common-law partnership or adoption (2) For the purpose of this Act, related persons, or persons related to each other, are (c) in any other case, it is a question of fact whether persons not related to each other are, at a particular time, dealing with each other at arm’s length. (b) a taxpayer and a personal trust (other than a trust described in any of paragraphs (a) to (e.1) of the definition trust in subsection 108(1)) are deemed not to deal with each other at arm’s length if the taxpayer, or any person not dealing at arm’s length with the taxpayer, would be beneficially interested in the trust if subsection 248(25) were read without reference to subclauses 248(25)(b)(iii)(A)(II) to (IV) and (a) related persons shall be deemed not to deal with each other at arm’s length ![]()
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