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Canada Revenue Agency · Active business & the small business deduction

Private-corporation restrictions

What the rule requires

ITA s. 89(1) keeps the corporation a private corporation for tax purposes by it not being, and not being controlled by, a public corporation. Restricted share transfers, a cap on holders and no public offering are the separate OBCA private-company mechanics that keep it there in practice.

Authority: ITA s. 89(1) ("private corporation"); OBCA

What goes wrong

The articles do not carry the full set of private-corporation restrictions.

What good looks like

Transfers are restricted, holders are capped at fifty and public offerings are prohibited. The corporation is drafted as a private corporation.

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The PREC Articles Health Check reads your articles of incorporation in your own browser and rates them Red, Yellow or Green against this criterion and 28 others. Your document is never uploaded to us.

An automated drafting scan, not legal or tax advice. It reads how the articles are drafted; it does not advise on your circumstances, and Capital Toolkit does not file articles with the Province.

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All Ontario PREC articles criteria