I-3 - Taxation Act

Section 592.5 Disposition versions

2017-02-08

592.5. For the purposes of this Part, the following rules apply:

(a)  equity interests in a non-resident corporation without share capital that have identical rights and obligations, determined without reference to proportionate differences in all of those rights and obligations, are deemed to be shares of a separate class of the capital stock of the corporation;

(b)  the corporation is deemed to have 100 issued and outstanding shares of each class of shares of its capital stock;

(c)  each person or partnership that holds, at any time, an equity interest in a particular class of the capital stock of the corporation is deemed to own, at that time, that number of shares of the capital stock of the particular class that is equal to the proportion of 100 that the fair market value, at that time, of all the equity interests of the particular class held by the person or partnership is of the fair market value, at that time, of all the equity interests of the particular class; and

(d)  shares of a particular class of shares of the capital stock of the corporation are deemed to have rights and obligations that are the same as those of the corresponding equity interests.

2017, c. 1, s. 146.