14 August 1990 Income Tax Severed Letter ACC9319 - Meaning of Share of the Capital Stock of a Family Farm Corporation

By services, 22 July, 2022
Official title
Meaning of Share of the Capital Stock of a Family Farm Corporation
Language
English
Document number
Citation name
ACC9319
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
656287
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1990-08-14 08:00:00",
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Main text
24(1)                                         W.P. Guglich
                                              (613) 957-2102

Attention 19(1)

Dear Sirs:

This is in reply to your letter of July 23, 1990 concerning the definition in paragraph 70(10)(b) of the term "share of the capital stock of a family farm corporation". In particular you are concerned with the words "actively engaged" in subparagraph 70(10)(b)(i) refer to a person who in his capacity as shareholder or employee was actively involved in the management and/or day to day activities of the farming business carried on by the corporation. The person would ordinarily be expected to contribute time, labour and attention to the business to a sufficient extent that such contributions would be determinant in the successful operation of the business. This is in contrast to a passive shareholder or investor who would not be considered to be "actively engaged".

We trust our comments will be of assistance.

Yours truly,

for Director Business and General Division Rulings Directorate Legislative and Intergovernmental Affairs Branch