Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 142.2 - Subsection 142.2(1) - Tracking Property	overview/purpose of tracking property	147
Tax Topics - Income Tax Act - Section 142.3 - Subsection 142.3(1)	overview of specified debt obligation rules	99

Fair Value Property

The determination of whether a property is fair value property "must be made in accordance with Canadian GAAP (which includes IFRS as applicable)...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 142.2 - Subsection 142.2(1) - Tracking Property	correlation sufficient/warrants included	187

Financial Institution

A new trust that is established with "seed money" contributed by a manager or sponsor that is a financial institution will itself be a financial...

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After noting that units of a mutual fund trust held by an insurance company (a "restricted financial institution") are not "mark-to-market...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Inventory	per Friesen, securities held on income account are inventory	85

Generally, a "tracking property" is defined in subsection 142.2(1) of the Act as a property the FMV of which is determined primarily by reference...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 142.2 - Subsection 142.2(1) - Excluded Property	overview of excluded property	173
Tax Topics - Income Tax Act - Section 142.3 - Subsection 142.3(1)	overview of specified debt obligation rules	99

The tracking property rules are anti-avoidance provisions which should be interpreted broadly. Therefore, there need not be a direct mechanism...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 142.2 - Subsection 142.2(1) - Fair Value Property		35