Section 122.1

Subsection 122.1(1) - Definitions

Gross REIT Revenue

Administrative Policy

23 December 2014 External T.I. 2014-0551841E5 - Subsections 44(1) and 69(11) of the Act

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 44 - Subsection 44(1) implied receipt of deemed s. 69(11) proceeds 119

Investment

Articles

Shane Onufrechuk, Warren Pashkowick, "Tax Considerations of Major Construction Projects", 2014 Conference Report, Canadian Tax Foundation, 10:1-35.

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Non-portfolio Property

Administrative Policy

16 April 2015 External T.I. 2014-0561061E5 - Specified Foreign Property

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 233.3 - Subsection 233.3(1) - Specified Foreign Property digital currency holdings of a foreign partnership not used in active business (para. (j)) 172

Articles

Carrie A. Bereti, Edward Rowe, "Cross-Border Income Trusts", International Tax, No. 61, December 2011, p. 1

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Real Estate Investment Trust

Administrative Policy

2014 Ruling 2014-0547491R3 - REIT entering into new LP

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 122.1 - Subsection 122.1(1) - Security call and put rights not securities 148

1 November 2010 External T.I. 2010-0368211E5 - Revenues of a REIT

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29 October 2010 External T.I. 2007-0244171E5 - SIFT Trust SIFT Partnership

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 122.1 - Subsection 122.1(1) - Rent from Real or Immovable Properties qualifying non-participating rent under hotel lease 86

Real or Immovable Property

Paragraph (b)

Administrative Policy

2011 Ruling 2010-0376801R3 - FIT Program (solar): revenue,

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Words and Phrases
ancillary

Rent from Real or Immovable Properties

Administrative Policy

29 October 2010 External T.I. 2007-0244171E5 - SIFT Trust SIFT Partnership

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 122.1 - Subsection 122.1(1) - Real Estate Investment Trust allocation of partnership revenue 80

Security

Administrative Policy

2014 Ruling 2014-0547491R3 - REIT entering into new LP

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 122.1 - Subsection 122.1(1) - Real Estate Investment Trust nil revenue satisfies the revenue tests/provision of guarantee for fee not a business 471

Subsection 122.1(1.2) - Character preservation rule

Administrative Policy

29 July 2011 External T.I. 2011-038551 -

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Subsection 122.1(2)

Administrative Policy

11 July 2008 External T.I. 2008-0267791E5 - normal growth guidelines -exchangeable units

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