Rulings Directorate Discussion and Position Paper on Motion Picture Films and Video Tapes as Tax Shelters, Version 29/3/93 930501 (C.T.O. "Motion Picture Films - C.C.A.")

"Revenue Canada could argue that it is not reasonable to allocate to the limited partners the losses referable to the partnership property for...

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RC will accept investors in film limited partnerships being accorded the right to put their units to an entity related to the film promoter...

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S.245(2) will be applied where CCA claims effectively are doubled-up by having Partnership B acquire all but one of the interests in Partnership A...

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Discussion in Appendix of techniques for postponement of realization of negative ACB by investors in film limited partnership. RC also states that...

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In an arrangement in which a creditor is entitled to all the income and losses following conversion of its loan into an interest in a film...

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RC will permit a film limited partnership to report its revenue (including revenue subject to a revenue guarantee) on a cash basis (on the...

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A letter of credit given by a financial institution to guarantee the payment of a prescribed revenue guarantee or the payment of a put of a film's...

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