Income Tax Technical News, No. 30, 21 May 2004

Although there is no impediment to the creation of partnership interests that carry different entitlements to share in the income or other...

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As noted earlier, loss consolidation transactions must be legally effective. ...However, we would not feel comfortable providing a ruling on a...

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The Agency "would not feel comfortable providing a ruling on a loss consolidation transaction that contemplates dollar amounts and time frames...

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Although, as a general rule the inclusion/deduction mechanism provided under ss.12(1)(a), 12(1)(e) and 20(1)(m) should apply to amounts received...

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The GE Capital case is consistent with the views of the Agency that at common law a rescission of a debt obligation will be implied when the...

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Under the scheme of the Act it is acceptable to transfer deductions within an affiliated group of corporations. The Agency will not feel...

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Remuneration received by a partner for work performed in the course of the partnership business is properly treated as a distribution of income or...

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Although there is no impediment to the creation of partnership interests that carry different entitlements to share in the income or other...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.