Section 188.1

Subsection 188.1(1) - Penalty — carrying on business

Articles

Joyce A. Young, H. Michael Dolson, "Income Tax Consequences of Carrying on an Unrelated Business", Business Vehicles, Volume XV, No. 1, 2012, p. 782, at 783, 784-785

The Minister's stated administrative position is that the nature and extent of services provided for, or made available to, tenants are important...

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Subsection 188.1(3.1)

Articles

Simon Cheung, "Private Foundations: Exceeding the 20 Percent Limit", Canadian Tax Focus, Vol. 9, No. 2, May 2019, p. 5

Eliminating the s. 188.1(3.1) penalty for a positive divestment obligation percentage (DOP)

[A] penalty is assessed for any year in which the...

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Subsection 188.1(3.2)

Administrative Policy

12 December 2018 Interpretation Letter of the CRA Charities Directorate to Simon Cheung File GC 341217

The Charities Directorate stated the following respecting a proposal to eliminate a foundation's positive divestment obligation percentage arising...

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Words and Phrases
interest

Subsection 188.1(4)

Administrative Policy

5 December 2019 Internal T.I. 2017-0683831I7 - Prescribed Rates and Undue Benefits

The Charities Directorate was encountering situations where a registered charity that is a private foundation makes a loan at the prescribed rate...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 189 - Subsection 189(1) use of prescribed rate does not insulate lender foundation from undue benefit rules 87

Subsection 188.1(7) - Incorrect information

Administrative Policy

Cathy Hawara, Director General, Charities Directorate, "The CRA Charities Directorate's Approach to Compliance", 2014 Conference Report, Canadian Tax Foundation, 37:1-10

1-10

Penalty for incorrect information (overview) (p. 37:6)

Every registered charity that issues, in a taxation year, a receipt for a gift...

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Subsection 188.1(9) - False information

Administrative Policy

Cathy Hawara, Director General, Charities Directorate, "The CRA Charities Directorate's Approach to Compliance", 2014 Conference Report, Canadian Tax Foundation, 37:1-10

1-10

Penalty for false information – fraudulent receipting also often results in revocation or criminal charges (pp. 37:6-7)

A person who makes...

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