Links from Section 587 | ||
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Act | Linked to | Context |
section 638A |
(2A)(a) In this subsection, “merger” and “division” have the same meaning as in section 638A. |
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Taxes Consolidation Act, 1997 |
(3) Subsection (2) shall apply in relation to a company which has no share capital as if references to shares in or debentures of a company included references to any interests in the company possessed by members of the company, and sections 584 and 586 shall apply accordingly. |
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Taxes Consolidation Act, 1997 |
(2) Where under any arrangement between a company and the persons holding shares in or debentures of the company or any class of such shares or debentures, being an arrangement entered into for the purposes of or in connection with a scheme of reconstruction or amalgamation, another company issues shares or debentures to those persons in respect of and in proportion to (or as nearly as may be in proportion to) their holdings of the first-mentioned shares or debentures, but the first-mentioned shares or debentures are either retained by those persons or cancelled, then, those persons shall be treated as exchanging the first-mentioned shares or debentures for those held by them in consequence of the arrangement (any shares or debentures retained being for this purpose regarded as if they had been cancelled and replaced by a new issue), and accordingly section 586(1) shall apply to such exchange of shares or debentures. |
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Taxes Consolidation Act, 1997 |
(3) Subsection (2) shall apply in relation to a company which has no share capital as if references to shares in or debentures of a company included references to any interests in the company possessed by members of the company, and sections 584 and 586 shall apply accordingly. |
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Taxes Consolidation Act, 1997 |
(4)(a) In this subsection, “shares” has the same meaning as in section 586(3). |
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Taxes Consolidation Act, 1997 |
(ii) that person and the company are members of the same group (within the meaning of section 616) throughout the period commencing one year before and ending one year after the day the debentures, loan stock or other similar securities were issued, or |
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Taxes Consolidation Act, 1997 |
(d) This section shall not apply where the company issuing the shares or debentures is an investment undertaking within the meaning of section 739B. |
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Links to Section 587 (from within TaxSource Total) | ||
Act | Linked from | Context |
Taxes Consolidation Act, 1997 |
(1) Notwithstanding paragraph 13, an individual who has had shares appropriated to him or her in a year of assessment under an approved scheme established by a company (“the first-mentioned company”) shall, subject to subparagraph (2), be entitled to have shares appropriated to him or her in that year of assessment under an approved scheme established by another company (“the second-mentioned company”) if, in that year of assessment, the second-mentioned company acquires control, or is part of a consortium that acquires ownership, of the first-mentioned company under a scheme of reconstruction or amalgamation (within the meaning of section 587). |
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Taxes Consolidation Act, 1997 |
(1) In this paragraph “original shares” and “new holding” shall be construed in accordance with sections 584, 586 and 587. |
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Taxes Consolidation Act, 1997 |
(b) are deemed to be exchanged by virtue of section 587 for shares in the first company and shares in the second company, |
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Taxes Consolidation Act, 1997 |
in circumstances such that, under section 584 as that section applies by virtue of section 586 or 587, the original shares and the new holding are treated as the same asset. |
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Taxes Consolidation Act, 1997 |
(10) Where for the purposes of capital gains tax the time when a person acquired shares would be determined under section 584, 585, 586, 587 or 600, then, unless the person is to be treated under section 584(4) as giving or becoming liable to give any consideration, other than the old holding, for the acquisition of those shares, it shall be determined in the same way for the purposes of this section. |
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Taxes Consolidation Act, 1997 |
(b) References in this section to a disposal of shares include references to a disposal of an interest or right in or over the shares, and an individual shall be treated for the purposes of this section as disposing of any shares which he or she is treated by virtue of section 587 as exchanging for other shares. |
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Taxes Consolidation Act, 1997 |
(3) References in this Part to a disposal of shares include references to a disposal of an interest or right in or over the shares, and an individual shall be treated for the purposes of this Part as disposing of any shares which the individual is treated by virtue of section 587 as exchanging for other shares. |
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Taxes Consolidation Act, 1997 |
(b) in a case where section 584, 586 or 587 applies, the shares received in exchange for the shares so acquired, |
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Taxes Consolidation Act, 1997 |
(b) Where a quoted option to subscribe for shares in a company is dealt in within 3 months after the taking effect, with respect to the company granting the option, of any reorganisation, reduction, conversion or amalgamation to which section 584, 585, 586 or 587 applies (or within such longer period as the Revenue Commissioners may by notice in writing allow), the option shall for the purposes of section 584, 585, 586 or 587 be regarded as the shares which could be acquired by exercising the option, and section 548(3) shall apply for determining its market value. |
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Taxes Consolidation Act, 1997 |
(b) Where a quoted option to subscribe for shares in a company is dealt in within 3 months after the taking effect, with respect to the company granting the option, of any reorganisation, reduction, conversion or amalgamation to which section 584, 585, 586 or 587 applies (or within such longer period as the Revenue Commissioners may by notice in writing allow), the option shall for the purposes of section 584, 585, 586 or 587 be regarded as the shares which could be acquired by exercising the option, and section 548(3) shall apply for determining its market value. |
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Taxes Consolidation Act, 1997 |
(c) under any arrangements referred to in section 587(2), |
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Taxes Consolidation Act, 1997 |
(2)(a) In this subsection, “shares” includes stock, debentures and any interests to which section 587(3) applies and any option in relation to such shares, and references in this subsection to an allotment of shares shall be construed accordingly. |
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Taxes Consolidation Act, 1997 |
(1) Subject to section 587, where a company issues shares or debentures to a person in exchange for shares in or debentures of another company, section 584 shall apply with any necessary modifications as if the 2 companies were the same company and the exchange were a reorganisation of its share capital. |
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Taxes Consolidation Act, 1997 |
(3)(a) In this subsection, “shares” includes stock, debentures and any interests to which section 587(3) applies and also includes any option in relation to such shares. |
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Taxes Consolidation Act, 1997 |
(2) This section shall apply as on and from the 21st day of April, 1997, in respect of an arrangement between a company and its members, being an arrangement to which subsection (2) of section 587 applies by virtue of subsection (3) of that section, and where the company is an assurance company which carries on a mutual life business. |
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Taxes Consolidation Act, 1997 |
(4) Where in connection with the arrangement shares in the successor company are issued to a member of the assurance company concerned, and such shares are treated under section 587 as having been exchanged by the member for the interest in the company possessed by the member, those shares shall, notwithstanding section 584, be regarded for the purposes of section 552(1)— |
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Taxes Consolidation Act, 1997 |
(II) a company involved in a scheme of reconstruction or amalgamation under section 587 with a relevant company, |
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Taxes Consolidation Act, 1997 |
(II)a company involved in a scheme of reconstruction or amalgamation under section 587 with a relevant company, |
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Taxes Consolidation Act, 1997 |
(II) a company involved in the same scheme of reconstruction or amalgamation under section 587 with the relevant company, |
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Taxes Consolidation Act, 1997 |
(a) section 586 or 587 applies to shares in a company so as to equate them with shares in or debentures of another company, and |
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Taxes Consolidation Act, 1997 |
(7) Where by virtue of section 587 shares are to be treated as cancelled or extinguished as a result of a merger or division within the meaning of section 638A (inserted by the Finance Act 2017) and replaced by a new issue, references in this section to a disposal of shares include references to the occasion of the shares being so treated. |
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Taxes Consolidation Act, 1997 |
(d) the merger does not constitute or form part of a scheme of reconstruction or amalgamation within the meaning of section 587. |
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Taxes Consolidation Act, 1997 |
(2) Where this section applies, the merger shall be treated for the purposes of section 587 as if it were a scheme of reconstruction. |
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Taxes Consolidation Act, 1997 |
(5) Notwithstanding anything in section 586 or 587, in any case where— |
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Taxes Consolidation Act, 1997 |
(3) This section applies to any transaction, being a disposal of original shares which, if the original shares were not such as are mentioned in subsection (2) would result in the disposal not being treated as a disposal by virtue of sections 584 to 587; but does not apply to any transaction in relation to which section 751B applies. |
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Taxes Consolidation Act, 1997 |
(6) Subsections (4) and (5) shall have effect with the necessary modifications in relation to any computation made for the purposes of section 707(4) in a case where the original shares held by the company concerned and the new holding are treated as the same asset by virtue of any of sections 584 to 587. |
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Taxes Consolidation Act, 1997 |
(3) An event which, apart from section 584(3) as applied by section 586 or 587, would constitute the disposal of an asset giving rise to a chargeable gain or an allowable loss under the Capital Gains Tax Acts and the Corporation Tax Acts shall for the purposes of this section constitute such a disposal. |
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Taxes Consolidation Act, 1997 |
(5)(a) An event which, apart from section 584(3) as applied by section 586 or 587, would constitute the disposal of an asset shall for the purposes of this section constitute such a disposal. |
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Taxes Consolidation Act, 1997 |
(b) An event which, apart from section 584(3) as applied by section 586 or 587, would constitute the acquisition of an asset shall for the purposes of this section constitute such an acquisition. |