Subsection 5000(1)
Administrative Policy
1993 Administrative Letter 9336656 F - Paragraph 5000(1) of the Income Tax Regulations
In response to an expressed concern that a trust or corporation could inadvertently have excess foreign property where it undertook to...
Subsection 5000(1.2)
Administrative Policy
14 November 1996 External T.I. 9637605 - INTEREST IN POOLED FUND/MASTER TRUST
Where a pooled fund trust also is a master trust, an interest in the pooled fund trust will not be foreign property regardless of its status as a...
Subsection 5000(2)
Administrative Policy
30 November 1995 Ruling 9616773 - SWAP CONTRACT, MARKETABLE SECURITY
The cost amount to a fund of its investments in exchange-traded futures contracts is equal to the brokerage fees and other costs incidental to...
Subsection 5000(7)
Pooled Fund Trust
Administrative Policy
31 May 1999 External T.I. 9908915 - POOLED FUND TRUST, MULTIPLE TRUSTEES
Where a trust is established with two trust companies, both trustees should qualify as a trust company incorporated under the laws of Canada or a...
1997 Ruling 9711923 - : Qualilfied Limited Partnership
Favourable ruling given that a partnership that otherwise qualified as a qualified limited partnership would not cease to so qualify if it...
17 May 1995 External T.I. 9503895 - SECOND RELEVANT YEAR FOR POOLED FUND TRUST TESTS
General discussion of the addition of references to the "second relevant year".
18 April 1995 External T.I. 9500895 - POOLED FUND TRUSTS
The cost amount of a futures contract at the time it is entered into or acquired is equal to the brokerage fees and other costs incidental to...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 206 - Paragraph 206(1)(h) | 34 |
10 February 1995 External T.I. 9431795 - MARKETABLE SECURITIES
"The term 'marketable security' refers generally to a security that is capable of reasonably prompt conversion into cash and that is easily...
6 October 1994 External T.I. 9420745 - MASTER TRUST
"A Trust that is prescribed to be a master trust under section 5001 of the Income Tax Regulations ("Regulations") and that elects to be such a...
19 June 1992 External T.I. 5-921587
A unit which was acquired in a year throughout which the trust does not meet the required conditions will not be an interest in a pooled fund trust.
21 May 1991 T.I. (Tax Window, No. 3, p. 32, ¶1261)
The lending of qualified securities by a pooled fund trust as a result of a securities lending arrangement will constitute the investing of funds...
Articles
Krasa, "Income Tax Implications of Joint Investment by Pension Plans through a Private Pooled Fund Vehicle", 1997 Canadian Tax Journal, Vol. 45, No. 1, p. 1.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(o.4) | 0 |
Qualified Limited Partnership
Administrative Policy
2002 Income Tax Severed Letter 2002-013816D - AMENDMENT OF QLP RULING
The terms of the partnership agreement that provided that a limited partner would be excused or excluded from or to pay a particular investment...
2000 Ruling 1999-000857
An arrangement under which a general partner had the right to catch-up earnings after the limited partners were paid an initial return and before...
24 October 1996 External T.I. 9629875 - 30% LIMITED PARTNER INTEREST
A limited partnership which is formed with one general and one nominee limited partner prior to a public offering will not qualify under...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 5102 | 40 |