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Annex 5.6: Allotment References

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The taxation implications of company law reform

A discussion document

December 1993


Annex 5.6: Allotment References

Income Tax Act

  • 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.

Stamp and Cheque Duties Act

  • 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.

Estate and Gift Duties Act

  • Section 2(2) - Definition of term "disposition of property".

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