Subparagraph 212.3(9)(b)(ii)

Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4)	circular transactions to effect a s. 212.3(9)(b)(ii) PUC reinstatement abused that provision	172

Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation	proportionate distribution by LLP treated as dividend	128
Tax Topics - Income Tax Act - Section 90 - Subsection 90(2)	proportionate LLP distribution to three direct or indirect general or limited partners treated as dividend on single class of shares	110
Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(3)	two Canadian corporate partners immediately beneath the U.S. border are QSCs respecting investments made by lower-tier CRICs in a U.S. LLP	238

Variable A

Foreign Parent holds a majority position in Pubco through foreign subsidiaries (Foreign Holdco 2 and Foreign Holdco 1) which, in turn,...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(18) - Paragraph 212.3(18)(c) - Subparagraph 212.3(18)(c)(v)	exclusion where (10)(f) corp on-subscribes proceeds in FA investments	185
Tax Topics - Income Tax Act - Section 261 - Subsection 261(5) - Paragraph 261(5)(a)	cross-border PUC of both lower- and upper-tier CRICs computed both in Cdn$ and U.S.$ where lower-tier CRIC had U.S.$ EFC	348