Section 132

Subsection 132(1) - Capital gains refund to mutual fund trust

Commentary

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Administrative Policy

7 March 1995 External T.I. 9504095 - MUTUAL FUND TRUSTS - CAPITAL GAINS REFUND FOR QUEBEC

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21 September 1992 T.I. (Tax Window), No. 24, p. 20 ¶2183)

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Articles

Hugh Chasmar, "Mutual Fund 'Switch Funds'", Taxation of Corporate Reorganizations, Canadian Tax Journal, Vol. 46, No. 1, 1998, p. 172.

Subsection 132(4) - Definitions

Capital Gains Redemption

Administrative Policy

2002 Ruling 2001-009107A - Mutual Fund Trust-Capital Gains

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Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(6) distribution of capital gains on unit redemptions 132

Articles

Brian C. Weatherby, "Mutual Funds", 1985 Conference Report, C. 45

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Refundable Capital Gains Tax On Hand

Administrative Policy

7 August 2013 Internal T.I. 2013-0497961I7 - Refundable Capital Gains Tax On Hand

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Articles

Hugh G. Chasmar, Suzanie M.L. Chua, "Reorganizations of Investment Funds", 2001 Canadian Tax Journal, Issue No. 2

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Subsection 132(6)

Commentary

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See Also

Ontario Hydro v. Ontario (Labour Relations Board), [1993] 3 S.C.R. 327

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Lount Corp. v. A.-G. of Canada (1985), 19 DLR (4th) 304 (FCA)

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Words and Phrases
undertaking

Northern Telecom v. Communications Workers, [1980] 1 S.C.R. 115

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Baytrust Holdings Ltd. v. IRC, [1971] 1 WLR 1333 (Ch D)

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Words and Phrases
undertaking

Town of Beauport v. Quebec Railway, Light & Power Co. / Quebec Railway, Light & Power Co. v. Town of Beauport, [1945] S.C.R. 16

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Words and Phrases
undertaking

Administrative Policy

24 March 2015 External T.I. 2012-0470991E5 F - Mutual fund trust

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(21) flow-through to unitholder of capital gain designated by MFT 183
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose s. 39(4) presumption establishing expense non-deductibility 64
Tax Topics - Income Tax Act - Section 39 - Subsection 39(5) - Paragraph 39(5)(a) election can be made by leveraged day-trading MFT 183
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Shares capital v. income character determined at trust level 94

2013 Ruling 2013-0492731R3 - qualifying disposition -mutual fund trust

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Tax Topics - Income Tax Act - 101-110 - Section 107.4 - Subsection 107.4(1) elimination of REIT sub trust through s. 107.4 transfer to new "in house" MFT and s. 132.2 merger of MFT into REIT 644
Tax Topics - Income Tax Act - Section 132.2 - Subsection 132.2(1) - Qualifying Exchange elimination of REIT subtrust through s. 107.4 transfer to new "in house" MFT and s. 132.2 merger of MFT into REIT 97

2011 Ruling 2010-0386081R3 - Guarantee provided by MFT to sub-partnership

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2008 Ruling 2008-0273501R3 - Guarantee by a MFT

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2008 Ruling 2008-0271251R3 - Arrangements related to dealer's commission

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2007 Ruling 2007-0226891R3 - MFT issues guarantee notes issuedby whollyownedLP

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Income Tax Technical News, No. 34, 27 April 2006

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2006 Ruling 2004-0097111R3 - REIT providing a guarantee on co-owned property

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2006 Ruling 2006-0191881R3 - Witholding Tax Exemption

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30 August 2004 External T.I. 2004-006085 -

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2004 Ruling 2003-005422 -

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15 April 2003 External T.I. 2002-0167675 - Debt guaranteed by a Mutual Fund Trust

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2000 Ruling 2000-0007513 - Index Tracking Mutual Fund

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1999 Ruling 991832 [investment undertaking in 2-tier structure]

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2 July 1998 External T.I. 9728675 - MUTUAL FUND TRUSTS

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16 June 1997 External T.I. 9700175 - INVESTING OF FUNDS - 100%

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31 March 1994 Administrative Letter 9337012 - MUTUAL FUND TRUST INVESTING IN FUTURES - INCOME ACCOUNT

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1996 Ruling 960994 [futures and forwards]

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5 January 1995 Income Tax Technical News, No. 6

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27 October 1994 Internal T.I. 9421586 - REGISTERED INVESTMENT AND STOCK INDEX FUTURES CONTRACT

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(e) 25
Tax Topics - Income Tax Act - Section 204.6 - Subsection 204.6(1) no tax under s. 204.6 if qualify as an MFT/tax for quasi-MFT re futures contract based on transaction costs 139

22 June 1994 External T.I. 9413475 - COMMODITY FUTURES CONTRACTS

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31 March 1994 Administrative Letter 9337012 - MUTUAL FUND TRUST INVESTING IN FUTURES - INCOME ACCOUNT

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 132 - Subsection 132(6) commodity futures are investing but may be on income account 59
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedges 61

8 March 1991 T.I. (Tax Window, No. 2, p. 25, ¶1189)

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Tax Topics - Income Tax Act - Section 131 - Subsection 131(8) 35

25 January 1991 T.I. (Tax Window, Prelim. No. 3, p. 29, ¶1107)

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Articles

D. Cannon, "Income Trusts: The Interest (Deduction) Continues - A Review of Westshore Terminals Income Fund and Superior Propane Income Fund", 1997 Corporate Management Tax Conference Report, c. 4.

D. Williamson, "Real Estate Investment Trust", 1997 Corporate Management Tax Conference Report, c. 5.

David M. Williamson, "Recent Transactions - Income Fund Trust", Current Issues in Resource Taxation, Canadian Tax Foundation, 1997, p. 1D:10.

J. Brussa, "Royalty Trusts, Income Trusts and the Search for Yield", 1996 Conference Report 19:9-10.

Weatherby, "Mutual Funds", 1985 Conference Report, C. 43.

Paragraph 132(6)(b)

Administrative Policy

15 September 2020 External T.I. 2020-0854471E5 - Pension Corporation - Renting Furnished Apartment

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(o.2) - Subparagraph 149(1)(o.2)(ii) - Clause 149(1)(o.2)(ii)(A) the purchase and rental of furniture in a furnished apartment is assimilated to the apartment rental activity 203

Subparagraph 132(6)(b)(i)

Administrative Policy

Income Tax Technical News No. 34 27 April 2006

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6 April 2004 External T.I. 2004-0068221E5 - Debt Guaranteed by a Mutual Fund Trust

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2004 Ruling 2003-0054221R3 - "investing of funds" and guarantees

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Subparagraph 132(6)(b)(ii)

Administrative Policy

29 July 2019 External T.I. 2018-0784701E5 - Rent from real/immovable properties - furnishings

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Words and Phrases
rent
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 122.1 - Subsection 122.1(1) - Rent from Real or Immovable Properties rent for fully-furnished apartments is all rent 129

Paragraph 132(6)(c)

Administrative Policy

8 June 2020 External T.I. 2019-0822901E5 - Mutual Fund Trusts

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 4801 - Paragraph 4801(b) an individual and their registered plans can constitute multiple beneficiaries under the 150 MFT beneficiary test 159

Subsection 132(6.1) - Election to be mutual fund

Administrative Policy

29 March 2001 External T.I. 2001-0071825 F - Application de 132(6) et 132(6.1)

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Subsection 132(7) - Idem [Retention of status as mutual fund trust]

See Also

Covert et al. v. Minister of Finance of Nova Scotia, [1980] CTC 437, [1980] 2 S.C.R. 774

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Drafting Style 82

Administrative Policy

2006 Ruling 2006-0174351R3 - re-organization of income trust to royalty trust

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23 November 2004 External T.I. 2004-0056271E5 - income trusts as qualified investments

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17 September 2004 External T.I. 2003-004888 -

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28 November 2003 External T.I. 2003-003097 -

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20 November 2002 External T.I. 2002-0153635 - Exchange rights iss

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Articles

David W. Ross, "Non-Resident Unitholders - Impact on Status", Resource Sector Taxation, 2004, p. 76.