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Partnership interests are property under scheme of Act (p. 9: 10) [S]ince the Act treats a partnership interest as a separate capital property, and dispositions of such interests are taxed to the partner as a sale of capital property and not as though the partner sold a right to the partnership’s assets … it would be more appropriate for paragraph 12(l)(g) to generally not apply to dispositions of partnership interests for the same reasons discussed above, in the context of share sales. ...

Dalsin, "ECP-Related CDA Dividend “In the Course of a Winding Up” Pre-2017", Canadian Tax Highlights, Vol. 27, No. 8, August 2019, p. 1-- summary under Paragraph 88(2)(a) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(2)- Paragraph 88(2)(a) No increase to CDA balance from eligible capital amount until year end (p. 1) [I]n order for a capital dividend account (CDA) to arise out of a cumulative ECP gain, there had to be a negative balance in the account at the year-end that included the event …. ...

. … The Canadian treatment of US taxes paid by Canadian-resident members can lead to adverse tax results when there is a mismatch between the year when US tax is paid, and the year when income is distributed to the member. ...

. … [I]f the CRIC disposes of its interest in the partnership, subsection 92(4) may add an amount to the proceeds of disposition if, before that time, the FA paid a dividend to the partnership out of its pre-acquisition surplus (PAS) in respect of which the CRIC claimed a paragraph 113(1)(d) deduction. ...

(p. 1) Potential for subsequent connectedness to exempt a previously paid dividend Suppose, instead, that on March 31, being a day that Opco and Bankco are not connected, a dividend is paid both by Opco to the trust, and by the trust to Bankco – but on September 30, a share ownership change results in Opco and Bankco now being connected, so that the CRA position suggests that Pt. ...

IV tax to the payees aggregating to the same $138,333 – but which, crucially, is effectively allocated between the dividend recipients pro rata to the respective dividends: there is Pt. ...

(p. 1) Although the effect of loss of the SBD is to reduce (for example, by $30,000 federally) the tax deferral benefit of corporate earning of the active business income (ABI), Ontario and New Brunswick did not adopt a matching limitation – so that in Ontario, for example, a CCPC earning ABI of $500,000 and AAII of $150,000 can still obtain a tax-deferral benefit at the Ontario level of up to $41,500 annually. ...

If this occurs there would be the Barbican / Mid-West Abrasive issue regarding a legal obligation arising after the year in which the interest accrued not being sufficient for the interest to be deductible in the earlier year (or the later year when the legal obligation arose). ...

Delivery of the LME Warrants is not an alternative to delivery of the metal sold – because of the terms of the LME Contract and the nature of LME Warrants, delivery of Warrants amounts to delivery of the metal. ...

Recommendation to scrap s. 150(1.3) (p. 5) It is recommended that proposed s. 150(1.3) not be enacted and that beneficial ownership information be obtained some other way – for instance, requiring the beneficial owners, when they file tax returns of their own, to provide beneficial ownership information respecting the bare trust arrangements on those returns would be more efficient. ...