Section 197

Subsection 197(1) - Definitions

Non-Portfolio Earnings

Administrative Policy

10 January 2011 External T.I. 2010-0377081E5 - Meaning of non-portfolio earnings

Where a SIFT holds all the shares of a foreign affiliate, and the SIFT's only transactions with the foreign affiliate are loans to the foreign...

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Subsection 197(2) - Tax on partnership income

Articles

Colin Campbell, "Libility for the Tax on SIFT Partnerships: A Rejoinder", 2011 Canadian Tax Journal, Vol 59, p. 709

Suggests that the phrase "liable to" can create a liability to tax; and that, in any event, the creation of liability to tax, viewed as merely an...

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Brian Bloom, Brandon Wiener, "Has Parliament Failed To Charge the 'Tax on SIFT Partnerships?", 2011 Canadian Tax Journal, Vol 59, p. 1

The "liable to" wording of s. 197(2) fails to create an immediate obligation to pay the SIFT tax because it does not specify that such tax is to...

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