Administrative Policy
11 January 2012 T.I. 2010-0377991E5 -
where a corporation (intended to qualify as a mortgage investment corporation) has two classes of shares with identical attributes except that only one of the classes is entitled to bonus dividends, both classes of shares would qualify as common shares, so that s. 130.1(6)(e) (which is relevant only where there are holders of preferred shares) would not apply to require that the payment of dividends be ordered in the specified manner.
16 September 2004 T.I. 2004-008852 -
When asked whether Class A preferred shares of a particular corporation would be common shares, the Directorate noted that in Terminal Dock and Warehouse Co. Ltd. v. MNR (1959), 23 Tax ABC 40, the Tax Appeal Board indicated that whether shares fall within the definition of "common share" was a matter of construction of the relevant document.