Clarifying the tax treatment of transfers of Proprietary Club Shares held under Nominee or Trust Agreements, Dispensing with Prior Confirmatory Ruling Subject to Post-Audit Verification
Tax NotesA common issue for corporations holding proprietary club shares through officer-nominees is establishing that transfers such shares are not subject to Capital Gains Tax (CGT), Documentary Stamp Tax (DST), or Donor's Tax. Since proprietary club memberships are typically required to be registered in the name of a natural person, corporations often designate officers as nominees or trustees.
