Section 143.2

Subsection 143.2(1) - Definitions

Limited-recourse amount

Tax Shelter Investment

Articles

Bacal, Jadd, Thivierge, "Raised the Curtain for Act II: Tax Shelter Reform and the New Film Tax Credit Regime", 1997 Canadian Tax Journal, Vol. 43, No. 6, p. 1965.

Ewens, "Tax Shelter Analysis", The Taxation of Corporate Reorganizations, 1996 Canadian Tax Journal, Vol. 44, No. 4, p. 1207 and Vol. 44, No. 5, p. 1486.

Subsection 143.2(2) - At-risk adjustment

Cases

Madell v. Canada, 2009 DTC 6043, 2009 FCA 193

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Subsection 143.2(6) - Amount of expenditure

Articles

Donald H. Watkins, "The Tax-Shelter Rules: An Update", 1998 Conference Report, c.5.

Bacal, Jadd, Thivierge, "Raised the Curtain for Act II: Tax Shelter Reform and the New Film Tax Credit Regime", 1997 Canadian Tax Journal, Vol. 43, No. 6, p. 1965.

Subsection 143.2(7) - Repayment of indebtedness

See Also

O'Dea v. The Queen, 2009 DTC 912, 2009 TCC 295

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Tolhoek v. The Queen, 2007 DTC 247, 2006 TCC 681 (Informal Procedure)

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Words and Phrases
bona fide necessary

Administrative Policy

3 February 2000 TI 990688

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Paragraph 143.2(7)(a)

See Also

Cassan v. The Queen, 2017 TCC 174

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Words and Phrases
bona fide relate to
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts common law gift was vitiated by loan to donor at unreasonably low rate 746
Tax Topics - Income Tax Act - Section 143.2 - Subsection 143.2(12) although borrowing by taxpayers had a term of 9.3 years, they had a reasonable expectation of refinancing with the promoter’s assistance 466
Tax Topics - Income Tax Regulations - Regulation 7000 - Subsection 7000(2) - Paragraph 7000(2)(d) no requirement to accrue interest on index-linked note in a year when the return thereon was not determinable 577
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) interest on loan to acquire LP units was deductible as there was a prospect of gross income being allocated by LP in 19 years’ time 583
Tax Topics - Statutory Interpretation - Realization Principle amount should not be recognized until ascertainable 67
Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(c) gratuitous transfer is gift irresepctive of absence of benevolent intent 50

Subsection 143.2(615)

See Also

Tolhoek v. The Queen, 2007 DTC 247, 2006 TCC 681 (Informal Procedure)

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Subsection 143.2(12)

See Also

Cassan v. The Queen, 2017 TCC 174

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts common law gift was vitiated by loan to donor at unreasonably low rate 746
Tax Topics - Income Tax Act - Section 143.2 - Subsection 143.2(7) - Paragraph 143.2(7)(a) loans were not bona fide in that not handled with commerciality 655
Tax Topics - Income Tax Regulations - Regulation 7000 - Subsection 7000(2) - Paragraph 7000(2)(d) no requirement to accrue interest on index-linked note in a year when the return thereon was not determinable 577
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) interest on loan to acquire LP units was deductible as there was a prospect of gross income being allocated by LP in 19 years’ time 583
Tax Topics - Statutory Interpretation - Realization Principle amount should not be recognized until ascertainable 67
Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(c) gratuitous transfer is gift irresepctive of absence of benevolent intent 50