Section 135

Subsection 135(1) - Deduction in computing income

Administrative Policy

19 November 2013 External T.I. 2011-0414201E5 F - Coop, ristournes, société de personne

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(a) customers of LP rather than of members 176

22 July 2013 External T.I. 2012-0467231E5 - Patronage dividends and capital gains

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19 June, 1995 T.I. 950842 (C.T.O. "Patronage of Dividends by Non Co-op"

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13 March 1992 External T.I. 5-920029 -

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13 March 1992 T.I. (Tax Window, No. 18, p. 7, ¶1804)

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Subsection 135(2) - Limitation where non-member customer

Cases

The Queen v. Consumers' Co-Operative Refineries Ltd., 87 DTC 5409, [1987] 2 CTC 204 (FCA)

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Subsection 135(2.1)

Administrative Policy

25 February 2015 External T.I. 2013-0503941E5 F - Priority of subsections 135(2) or 135.1(3)

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Tax Topics - Income Tax Act - Section 135.1 - Subsection 135.1(3) non-deductible excess cannot be carried forward 127

Subsection 135(4) - Definitions

Allocation in Proportion to Patronage

Administrative Policy

14 December 2012 External T.I. 2012-0436981E5 F - Ristournes de coopératives de travailleurs

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19 June 1995 Memorandum 950842 (C.T.O. "Patronage Dividends Paid by Non Co-ops")

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Tax Topics - General Concepts - Payment & Receipt 27

27 March 1995 External T.I. 9431975 - PATRONAGE DIVIDENDS

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7 June 1993 T.I. (Tax Window, No. 31, p. 23, ¶2549)

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26 August 1992 T.I. (Tax Window, No. 23, p. 19, ¶2138)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 135 - Subsection 135(7) 29

Customer

Administrative Policy

29 January 2018 External T.I. 2017-0702731E5 - Patronage dividends and partnerships

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Tax Topics - Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(a) partnership rather than member was taxpayer for patronage dividend purposes 76

Income of the Taxpayer Attributable to Business Done With Members

Cases

Interprovincial Co-operative Ltd. v. The Queen, 87 DTC 5115, [1987] 1 CTC 222 (FCTD)

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Tax Topics - General Concepts - Onus 60
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) property acquired only because parent so directed 90

Sedgewick Co-operative Association Ltd. v. The Queen, 83 DTC 5455, [1984] CTC 14 (FCTD)

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Administrative Policy

29 February 2016 External T.I. 2015-0613961E5 - Patronage dividends - partnership income

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(f) flow-thrugh of LP income for s. 135 purposes 74

Subsection 135(7) - Payment to customer to be included in income

Administrative Policy

9 December 2010 External T.I. 2010-0364001E5 F - Ristourne de consommation, feuillet T4A

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Tax Topics - Income Tax Regulations - Regulation 218 T4A required where annual payments in proportion to patronage exceed $500 96

26 August 1992 T.I. (Tax Window, No. 23, p. 19, ¶2138)

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