Subtopics
- 10/8 Policy
- Active Business
- Amortized Cost
- Amount
- Annuity
- Assessmen
- Automobile
- Borrowed Money
- Business
- Business Number
- Canadian Resident Partnership
- Common-Law Partner
- Common Share
- Corporation
- Cost Amount
- Death Benefit
- Depreciable Property
- Derivative Forward Agreement
- Disposition
- Dividend
- Dividend Rental Agreement
- Eligible Capital Property
- Eligible Relocation
- Employee
- Employee Benefit Plan
- Employment
- Farming
- Fiscal Period
- Former Business Property
- Graduated Rate Estate
- Gross Revenue
- Group Term Life Insurance Policy
- Income Bond
- Indexed Debt Obligation
- Individual
- International Shipping
- International Shipping
- International Traffic
- Inventory
- Joint Spousal or Common-law Partner Trust
- Legal Representative
- LIA Policy
- Mineral Resource
- Net Income Stabilization Account
- Office
- Pension Fund or Plan
- Person
- Personal or Living Expenses
- Personal Trust
- Prescribed
- Principal Amount
- Private Health Services Plan
- Property
- Qualified Canadian Journalism Organization
- Qualified Environmental Trust
- Recognized Stock Exchange
- Registered Canadian Amateur Athletic Association
- Registered Charity
- Registered Journalism Organization
- Retirement Compensation Arrangement
- Retiring Allowance
- Salary Deferral Arrangement
- Salary or Wages
- Scientific Research & Experimental Development
- Self-Contained Domestic Establishment
- Share
- Shareholder
- Short-Term Preferred Share
- Small Business Corporation
- Specified Financial Institution
- Specified Member
- Specified Shareholder
- Subsidiary Controlled Corporation
- Superannuation or Pension Benefit
- superannuation or pension fund or plan
- Synthetic disposition arrangement
- Synthetic Equity Arrangement
- Tax-Indifferent Investor
- “Tax Treaty”
- Taxable Canadian Property
- Taxable Preferred Share
- Taxation Year
- Taxpayer
- Term Preferred Share
- Treaty-Protected Business
Cases
Canada v. Green, 2017 FCA 107
Webb JA stated (at para. 22) that “since partnerships are not taxpayers for the purposes of sections 3 and 111, these sections do not apply to...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 96 - Subsection 96(2.1) | business losses of lower-tier LPs flowed through upper-tier partnership | 542 |
| Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(e) | upper-tier LP not required to compute income and therefore not subject to s. 111(1)(e) | 115 |
| Tax Topics - Income Tax Act - 101-110 - Section 102 - Subsection 102(2) | ITA recognizes 2-tier partnerships | 72 |
Administrative Policy
26 May 2023 External T.I. 2022-0946411E5 - Classification of an Intermunicipal Management Board
A municipality may acquire an interest in a Canadian renewable energy project through an intermunicipal management board (“IMB”), which...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(26) - Paragraph 1100(26)(b) | an intermunicipal management board is a corporation/ no finding on principal business | 273 |
21 November 2017 CTF Roundtable Q. 15, 2017-0724091C6 - Conversion from a US LP to an LLC
The conversion of a U.S. LP to an LLC would result in a disposition of the partnership interests and assets at FMV with the ACB of the acquired...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f) | an LLC resulting from a conversion from a US LLC has high inside and outside basis | 254 |
2017 Ruling 2017-0687061R3 - Whether re-designation of LPUs is a disposition.
Background
The Partnership is a limited partnership which invests in securities chosen by its manager on a discretionary basis and all of whose...