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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20 September 2005 External T.I. 2005-0140601E5 F - Ristournes - Coop de travailleurs actionnaire
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19 June, 1995 T.I. 950842 (C.T.O. "Patronage of Dividends by Non Co-op"
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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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Amount | allocation in proportion to patronage could be made at a zero rate | 18 |
| Tax Topics - Statutory Interpretation - Absurdities | 49 |
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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| Locations of other summaries | Wordcount | |
|---|---|---|
| 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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6 October 2005 External T.I. 2005-0146061E5 F - Coop de travailleurs actionnaire - montants versés
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 82 - Subsection 82(1) - Paragraph 82(1)(a) | interest on a preferred share was a dividend | 27 |
| Tax Topics - Income Tax Act - Section 136 - Subsection 136(2) | workers shareholder cooperative qualified | 108 |
19 June 1995 Memorandum 950842 (C.T.O. "Patronage Dividends Paid by Non Co-ops")
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| Locations of other summaries | Wordcount | |
|---|---|---|
| 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)
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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| Locations of other summaries | Wordcount | |
|---|---|---|
| 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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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Onus | 62 | |
| Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) | property acquired only because parent so directed | 92 |
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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| Locations of other summaries | Wordcount | |
|---|---|---|
| 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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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 135 - Subsection 135(4) - Allocation in Proportion to Patronage | 41 |