Jack Silverson, Bill Corcoran, "Issues Affecting Investments by Canadian Pension Plans in Private Equity, Infrastructure and Real Estate in Canada, the USA and Europe", 2016 Conference Report (Canadian Tax Foundation),15:1-40

Summary Under
Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(o.2) - Subparagraph 149(1)(o.2)(iii)

Interpretation of 10% limit in PBSA Regulations, Sched. III, s. 9(1) (“10% Rule”) (pp. 15:4-6)

The purpose of the 10 percent rule was also...

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Words and Phrases
derived
Summary Under
Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(o.2) - Subparagraph 149(1)(o.2)(ii)

Use of lease structure to address proportionate activity or real estate activity tests (pp. 15:19-23)

Pension plan investments in real estate are...

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Summary Under
Tax Topics - Treaties - Multilateral Instrument - Article 7

Application of PPT to a Canadian pension fund co-investing in Europe through e.g. a Luxco (pp. 15:32-35)

A pension plan seeking to invest in...

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