Section 102

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 81

3 February 1992 T.I. (Tax Window, No. 16, p. 20, ¶1727)

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18 November 1991 Memorandum (Tax Window, No. 11, p. 6, ¶1536)

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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 526
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) 113
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) partnerships not taxpayers for ss. 3 and 111 purposes 39

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 302

Major v. Brodie & Anor, [1998] BTC 141 (Ch. D)

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Administrative Policy

91 C.R. - Q.3

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Articles

Allgood, "Recent Developments in Asset-Backed Securitization", 1993 Conference Report, c. 16

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