Subsection 99(1) - Fiscal period of terminated partnership
See Also
MacDonellv. MNR, 54 DTC 14 (ITAB)
The withdrawal by the taxpayer from a firm of chartered accountants did not lead to any change in the partnership's fiscal period in light inter...
Administrative Policy
2016 Ruling 2015-0617101R3 - 99(1) and timing of ACB adjustment
The sole limited partner (LPco) transfers it interest in an LP under s. 85(1) to the general partner (GPco), thereby triggering the simultaneious...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(i) | ACB of limited partner’s and GP’s interest increased by YTD income on s. 98(6) wind-up arising on GP’s s. 85 purchase of limited partner’s interest | 304 |
| Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) | on a s. 98(5) wind-up, the ACB of the transferor partner’s interest is bumped by YTD income | 105 |
6 January 2014 External T.I. 2013-0477711E5 - Limited partnership losses and dissolution
A sale of assets by a limited partnership before a cessation of its operations resulted in a terminal loss. Before addressing an at-risk amount...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 96 - Subsection 96(2.1) | partnership termination | 124 |
15 July 2008 External T.I. 2008-0275471E5 F - Société de personnes/Ajustement au PBR
Pending the amendment to s. 99(1), will CRA apply the Act such that the income or loss of a partnership for its last taxation year before its...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(i) | CRA intent to avoid double taxation from untimely basis adjustment for earned income | 45 |
Subsection 99(2) - Fiscal period of terminated partnership for individual member
Cases
Darke v. MNR, 76 DTC 6468, [1976] CTC 734 (FCTD)
Sweet, D.J. stated, obiter, that "the end of the term of a partnership and the completion of the winding up of its affairs may not necessarily be...