Annex 5.6: Allotment References

The taxation implications of company law reform

A discussion document

December 1993

Section 3(1)(a),(2) - Definition of term "bonus issues".
Section 7(4) - Defining when two companies consist substantially of the same shareholders.
Section 8(1)(b) - Defining when a company and an individual are associated persons.
Section 67(2)(b) - Profits or gains from land transactions.
Section 150(1)(d),(e) - Contributions to employees' superannuation schemes.
Section 166(2)(b) - Notional interest on loans made to employees under employee share purchase scheme.
Section 194(1)(f) - Deduction for dividends paid on specified preference shares issued before 23 October 1986.
Section 204M(3) - Non-resident life insurer may elect to be treated as resident life insurer.
Section 214E(1)(b) - Petroleum mining operation regime associated persons definition.
Section 218(3),(10) - Profits or gains from sale of mining shares by companies.
Section 226(1) - Definition of term "disposition of property" in the interpretation section in the trust regime.
Section 393F(3) - Period of grace for certain new qualifying company regime elections.
Section 393O(2) - Revocation of loss attributing qualifying company elections and new elections.
Section 394A(1) - Definition of term "paid" in the interpretation provision of the imputation regime.

Section 2 - Definition of term "instrument of nomination of shares".
Section 7(h),(k) - Meaning of expression "instrument of conveyance" extended.
Section 47(1)(b) - Valuation of consideration.
Section 90(1) - Offence to issue certain shares unless pursuant to duly stamped instrument of nomination.