Michael N. Kandev, Sandra Slaats, "Recent Developments in the Foreign Affiliate Area", 2015 Annual CTF Conference paper

Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation

CRA position on partnerships under the Delaware Revised Uniform Partnership Act (p. 31:5)

Effectively, the CRA concluded [in ITTN No. 20, June 14,...

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Summary Under
Tax Topics - Income Tax Act - Section 96

CRA position on partnerships under the Delaware Revised Uniform Partnership Act (p. 31:5)

Effectively, the CRA concluded [in] ITTN No. 20, June...

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Summary Under
Tax Topics - Income Tax Act - Section 90 - Subsection 90(9)

Inappropriate reduction of reserve by blocking deficit of intermediate FA Holdco (pp. 31:31-31:34)

One of the fundamental issues with the reserve...

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