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Yours truly, Patricia Spice for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

We trust our comments will be assistance to you, Yours truly, Patricia Spice for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

The legislation for this triggering event reads "... the transferor is deemed to own a property... until the time... after the particular time, (A) at which a 30-day period begins throughout which neither the transferor nor a person affiliated with the transferor owns or has a right to acquire the transferred property... ...

Yours truly, Patricia Spice for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

Yours truly, Patricia Spice for Director Financial Industries Division Income Tax Rulings Directorate Policy & Legislation Branch ...

A partnership's business income / loss is allocated to each partner to the extent of that partner's share. ...

Diguer CGA Attention: XXXXXXXXXX October 4, 2000 Dear Sir: Re: Short Term Preferred Share This is in reply to your letter dated July 12, 2000 in which you request the Canada Customs & Revenue Agency's (the "Agency") views concerning the application of paragraph (a) of the definition of short-term preferred share (the "Definition") contained in subsection 248(1) of the Income Tax Act (Canada) (the "Act"). ...

As the preamble to Regulation 201(1) applies where a "... person... makes a payment" it appears that the provision would require the making of the information return by each person that is a member of the partnership to the extent of that person's share of the payment. ...

Although subsection 102(2) provides that "... a reference to a person or a taxpayer who is a member of a particular partnership shall include a reference to another partnership that is a member of the particular partnership", it is a limited deeming provision and does not deem the partnership that continues the business to be either "one" person or to carry on "alone" the business, which are prerequisites for the application of subsection 98(5). ...

(see Koop, Klassen & Rushton (Youth for Christ Employee) XXXXXXXXXX 2000-006144 C. ...