Subsection 181.5(6)
Administrative Policy
19 October 2000 External T.I. 2000-0027795 F - SOCIETES PRIVEES SOUS CONTROLE CDN
corporations controlled by the provincial Crown would not be required to share their capital deduction
Corporations controlled (but less than 90% owned) by a Crown corporation in which a provincial government was a 100% shareholder would otherwise be related pursuant to ss. 251(2)(b)(i), 251(2)(c)(i) and (ii) with all other corporations controlled by that provincial government given inter alia that the provincial Crown was a person. However, s. 181.5(6) indicated that they would not be related for the purposes of calculating the capital deduction.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 125 - Subsection 125(3) | corporations controlled by the provincial Crown, required to share their business limit | 58 |
| Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Canadian-Controlled Private Corporation | corporations controlled by the provincial Crown treated as CCPCs | 61 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Person | provincial Crown is a person | 20 |
Subsection 181.5(7) - Related corporations that are not associated
Administrative Policy
18 January 1993 T.I. (Tax Window, No. 28, p 14, ΒΆ2374)
The election in s. 256(2) applies for purposes of the small business deduction only and has no effect for purposes of s. 181.5(7).