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Consequently, each of the employees of the partnership are considered to be employees of each of the partners of the partnership for the purposes of section 7. ...

2023 Ruling 2022-0950461R3- Continuation of a Bermudian LP to a Delaware LP-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 Bermuda partnership that was domesticated under the DRULPA continued as a partnership Regarding the “domestication” of an exempted Bermuda limited partnership to become a limited partnership governed by the Delaware Revised Uniform Limited Partnership Act (the “DRULPA”), CRA accepted a representation that the partnership activity (of holding shares of subsidiaries) was carried on in common with a view to a profit and that the partnership was considered a partnership for purposes of the Act prior to the domestication transaction, and ruled that following the domestication, the partnership will be treated as a partnership for purposes of the Act. ...

15 October 2004 Ruling RITS 52698-- summary under Paragraph 142(1)(c) Summary Under Tax Topics- Excise Tax Act- Section 142- Subsection 142(1)- Paragraph 142(1)(c) situs of supply where resort points seized In connection with rulings on the consequences of the seizure by creditors and resale by them of resort points, the Directorate noted that the portion of sold resort points that was considered to be supplied in Canada was determined by prorating the consideration payable by a recipient of resort points based on the extent to which the resort points represented a right to use real property situated in Canada. ...

Rulings IT-392, para. 3 regarding the meaning of "share" will apply to DC such that Holdco and Newco will be considered to own shares of DC. ...

The trailer is considered to come within "any other similar premises" in the definition in s. 123(1) of a residential unit. ...

The trailer is considered to come within "any other similar premises" in the definition in s. 123(1) of a residential unit. ...

Subco 3, as the non-surviving corporation in this merger, will be considered to have disposed of all its assets and liabilities to Absorbco for their fair market value except that the shares of Absorbco instead will be disposed of by the non-resident parent of Subco 3 at fair market value. ...

With respect to the issue as to whether payments under the arrangement were considered to be something other than a pension due to the short period (12 years) before vesting occurred, the Department was of the view that a pension of 30% after 12 years of service was commensurate with a normal pension of 70% after 35 years. ...

[and] [f]or this purpose, ACo will not be considered to have been wound up until it has been formally dissolved. ...

Ruling that the transfers from the Direct Subtrusts to Trust A in 2 will not be considered a "disposition" by virtue of s. 248(1) – disposition, (f)(v), and Trust A will be deemed, to be the same trust as, and a continuation of, each of the Direct Subtrusts by virtue of s. 248(25.1); therefore the ACB of Taxpayer's interest in Trust A will be equal to the aggregate ACB of Taxpayer's interests in the Direct Subtrusts before the transfer. ...