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Administrative Policy summary
Income Tax Mandatory Disclosure Rules Consultation: Sample Notifiable Transactions (Finance Release Webpage), 4 February 2022 -- summary under Subsection 237.4(3)
A taxpayer seeks to avoid the s. 18(19) straddle-transaction rules by acquiring a partnership interest in a partnership that had an accrued loss and gain on the two legs of an FX straddle, with the closing of such acquisition being immediately preceded by the closing out by the partnership of the gain leg so that such gain is allocated to the vending partner pursuant to s. 96(1.01) – and with the loss leg realized after the acquisition and allocated to the taxpayer. ...
Administrative Policy summary
GST/HST Memorandum 18-4 “Determining Whether a Transfer Payment is Consideration For a Supply” June 2022 -- summary under Consideration
Example 8 A municipality provides a transfer payment to an NPO to build a sports facility on municipal land (the primary purpose is to acquire the facility – there is a direct link). ...
Administrative Policy summary
S3-F3-C1 - Replacement Property -- summary under Former Business Property
Voluntary disposition of Class 14.1 property generally not eligible for replacement property rules. 1.46 … One of the characteristics of a former business property is that the property is real or immovable property or an interest therein. ...