Bruce Sinclair, "Current Topics in the Taxation of Real Estate Development", 2014 Conference Report, (Canadian Tax Foundation), 12:1-24.

Summary Under
Tax Topics - Income Tax Act - Section 160 - Subsection 160(1)
Sale of Projectco before allocation to it by sub LP of condo sale profits (pp. 12:2-3)

Developers often undertake projects in a single-purpose...

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Summary Under
Tax Topics - Income Tax Act - Section 55 - Subsection 55(2)
Sale of Projectco before allocation to it by sub LP of condo sale profits (pp. 12:2-3)

Developers often undertake projects in a single-purpose...

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Summary Under
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(a) - Subparagraph 95(2)(a)(i)
Non-application of hypothetical income test where mother ship is subsidiary management LP (p. 12:21)

[C]lause (B)…does not have to be met where...

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