Alan Kenigsberg, "Changes to Tax Treatment of ILPs under the ETA", Sales Tax, Customs & Trade, Volume XV, No 2, Federated Press, 2018, p.9

Summary Under
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Investment Limited Partnership

Purpose of ILP rules (p. 9)

We understand that the new measures were aimed at preventing certain investment funds from structuring their affairs...

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Summary Under
Tax Topics - Excise Tax Act - Section 217.1 - Subsection 217.1(1)

Aborted proposal to extend qualifying taxpayer rules to non-resident LPs (p. 12)

When the Department of Finance first announced that it was...

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Summary Under
Tax Topics - Excise Tax Act - Section 272.1 - Subsection 272.1(8)

Self-assessment within a FMV range (p. 14)

[I]f the transfer pricing model … were adopted, a transfer pricing-like study would often generate a...

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