Subsection 102(1)
Administrative Policy
26 January 2015 External T.I. 2014-0547501E5 - Certificates of residency and partnerships
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 2 - Subsection 2(1) | certification of Canadian partnership at request of authorized representative | 91 |
3 February 1992 T.I. (Tax Window, No. 16, p. 20, ¶1727)
18 November 1991 Memorandum (Tax Window, No. 11, p. 6, ¶1536)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(2) | 43 |
Subsection 102(2) - Member of a partnership
Cases
Canada v. Green, 2017 FCA 107
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 96 - Subsection 96(2.1) | business losses of lower-tier LPs flowed through upper-tier partnership | 542 |
| Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(e) | upper-tier LP not required to compute income and therefore not subject to s. 111(1)(e) | 115 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) | partnerships not taxpayers for ss. 3 and 111 purposes | 41 |
See Also
Devon Canada Corporation v. The Queen, 2013 TCC 415
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 66.7 - Subsection 66.7(10) - Paragraph 66.7(10)(j) | drop-down to 2nd tier partnership following deemed successoring | 320 |
Major v. Brodie & Anor, [1998] BTC 141 (Ch. D)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 253.1 | top tier partners are lower tier partnership members | 242 |
| Tax Topics - Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(f) | 242 | |
| Tax Topics - Statutory Interpretation - Provincial Law | 97 |
Administrative Policy
Articles
Allgood, "Recent Developments in Asset-Backed Securitization", 1993 Conference Report, c. 16
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Timing | 18 | |
| Tax Topics - Income Tax Regulations - Regulation 7000 - Subsection 7000(1) - Paragraph 7000(1)(b) | 15 |