Income Tax Severed Letters - 2014-09-17

Ruling

2014 Ruling 2014-0526361R3 F - Post Mortem Pipeline

CRA Tags
84.1(1), 245(2), 84(2)
step up of PUC of freeze pref shares for purposes of pipeline transaction
step up of PUC of freeze pref shares for purposes of pipeline transaction

Principales Questions: Post Mortem Planning

Position Adoptée: Favourable rulings provided

Raisons: Meets the requirements of the law.

Technical Interpretation - External

18 August 2014 External T.I. 2014-0528001E5 - Fiscal period of a partnership

CRA Tags
249.1(1), (4).
corporate sub of upper-tier partnership is member of lower-tier partnership
corporate sub of upper-tier partnership is member of lower-tier partnership

Principal Issues: Would paragraph 249.1(1)(c) of the Act apply to a partnership if its wholly-owned corporation becomes a member of another partnership?

Position: No. A partnership's indirect investment in another partnership through its wholly-owned corporation would not, in and of itself, cause the partnership to be within the ambit of paragraph 249.1(1)(c).

Reasons: Paragraph 249.1(1)(c) is concerned with tiered partnership structures and contemplates a membership interest in a partnership that is held directly, or indirectly through one or more partnerships, by a partnership.