Timothy Hughes, Matias Milet, Marc Richardson-Arnould, "Private Equity Funds – Selected Canadian Tax Issues", Tax Management International Journal, 2016, p.84

Summary Under
Tax Topics - Income Tax Act - Section 115.2 - Subsection 115.2(2) - Paragraph 115.2(2)(b)

Restrictions on s. 115.2 safe harbour (p. 86)

The safe harbour contains a number of restrictions. For example, a share in the capital stock of a...

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Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Taxable Canadian Property - Paragraph (d)

Goodwill fluctuations relative to real estate may potentially taint private equity investments (p. 86)

Private equity funds currently invest...

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Summary Under
Tax Topics - Treaties - Income Tax Conventions - Article 10

Advantages of separate fund for Canadian investors (p. 87)

A non-Canadian private equity fund that expects to have significant investor capital...

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