Philippe Montillaud, Grant J. Russell, "Foreign Accrual Tax and Flow-through Entities", International Tax Planning, Volume XVIII, No. 4, 2013, p. 1280

Summary Under
Tax Topics - Income Tax Act - Section 91 - Subsection 91(4.5)
No relief where PPOP is the hybrid (p. 1281)

Subsection 91(4.5) does not provide relief, however, where the PPOP itself is the hybrid entity. For...

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Summary Under
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(e)
Application of s. 93(2.01) stop-loss rule to DLAD capital loss (p. 1282)

Regulation 5907(5) requires that capital gains and losses for surplus...

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Summary Under
Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(5)
Application of s. 93(2.01) stop-loss rule to DLAD capital loss (p. 1282)

Regulation 5907(5) requires that capital gains and losses for surplus...

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