Section 149

Table of Contents

Subsection 149(1) - Miscellaneous exemptions

Paragraph 149(1)(a) - Employees of a country other than Canada

Administrative Policy

14 January 2014 External T.I. 2013-0510061E5 - Foreign doctors working in Canada

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Paragraph 149(1)(c) - Municipal authorities

See Also

Laval Technopole v. Agence du revenu du Québec, 2018 QCCQ 6352

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(3) - Fully exempt interest - Paragraph (a) - Subparagraph (a)(iii) traditional common law tests of Crown agency applied in determining whether companies were agents of Canadian municipalities 268
Tax Topics - General Concepts - Agency 184

Administrative Policy

10 December 2014 Internal T.I. 2014-0533151I7 - Qualified Donee - XXXXXXXXXX

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2014 Ruling 2012-0473041R3 - First Nation - Limited Partnership

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2013 Ruling 2012-0472821R3 - 149(1)(c) Ruling

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11 June 2014 Internal T.I. 2014-0521411I7 - 149(1)(c)

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2013 Ruling 2013-0488661R3 - Indian Band -Public Body & Function of Government

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12 August 2013 External T.I. 2013-0498891E5 - public body performing a function of government

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7 March 2013 Internal T.I. 2011-0428491I7 - Paragraph 149(1)(c)

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2012 Ruling 2012-0445071R3 - 149(1)(c) Ruling

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2004 Ruling 2004-008032 -

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2004 Ruling 2004-006020 -

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 75 - Subsection 75(2) 50

4 August 1995 External T.I. 5-951992 -

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92 C.R. - Q.36

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Articles

J. Peter Ranson, "The Evolution of Aboriginal Tax Exemptions: The Past, the Present and the Future", 2005 Conference Report, c. 24.

Sara K. McCracken, "Municipal Corporations: One Option for First Nations Businesses", Business Vehicles, Vol. VI, No. 3, 1999, p. 2406.

Paragraph 149(1)(d) - Corporations owned by the Crown

See Also

Nova Scotia Power Inc. v. The Queen, 2002 DTC 1432 (TCC)

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Otineka Development Corp. Ltd. v. The Queen, 94 DTC 1234 (TCC)

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Words and Phrases
municipality

Administrative Policy

6 July 2001 External T.I. 2001-008157 -

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13 July 1995 External T.I. 5-950326 -

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29 March 1994 T.I. 940775 (C.T.O. "Right of Redemption")

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11 January 1993 Memorandum (Tax Window, No. 28, p. 19, ¶2387)

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8 September 1992 T.I. (Tax Window, No. 24, p. 16, ¶2182)

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Articles

J. Peter Ranson, "The Evolution of Aboriginal Tax Exemptions: The Past, the Present and the Future", 2005 Conference Report, c. 24.

Paragraph 149(1)(d.3) - 90% owned corporations

Administrative Policy

2003 Ruling 2002-016808 -

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Paragraph 149(1)(d.4) - Combined ownership

Administrative Policy

12 October 2012 External T.I. 2011-0428521E5 F - Société d'État

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Paragraph 149(1)(d.5) - Income within boundaries of entities

See Also

Lawyers' Professional Indemnity Company v. The Queen, 2018 TCC 194

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Administrative Policy

5 January 2016 External T.I. 2015-0568911E5 F - MRC - Revenu d’entreprise

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 256 - Subsection 256(5.1) test references dominant person 84

2 December 1999 T.I. 991389

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Articles

Sara K. McCracken, "Municipal Corporations: One Option for First Nations Businesses", Business Vehicles, Vol. VI, No. 3, 1999, p. 2406.

Paragraph 149(1)(e) - Certain organizations

Administrative Policy

2013 Ruling 2012-0438831R3 - 149(1)(e) Ruling

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11 June 1993 Memorandum (Tax Window, No. 32, p. 21, ¶2625)

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Paragraph 149(1)(f) - Registered charities

Cases

Canada v. Nova Scotia Power Inc., 2003 DTC 5090, 2003 FCA 33

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Paragraph 149(1)(i) - Certain housing corporations

Administrative Policy

11 July 1994 External T.I. 7-941446 -

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Paragraph 149(1)(j) - Non-profit corporations for scientific research and experimental development

Administrative Policy

21 February 2013 External T.I. 2012-0442751E5 F - Non-Profit SR&ED corporation

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 37 - Subsection 37(1) - Paragraph 37(1)(a) - Subparagraph 37(1)(a)(ii) - Clause 37(1)(a)(ii)(A) requirements for approval under (A) or (B) of research association 192

5 May 1995 External T.I. 5-942198 -

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19 October 1993 Memorandum 932981 (C.T.O. "Approved for Scientific Research")

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18 May 1993 T.I. (Tax Window, No. 31, p. 8, ¶2517)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 37 - Subsection 37(1) 11

4 August 1992 T.I. (Tax Window, No. 23, p. 9, ¶2166)

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11 January 1990 T.I. (June 1990 Access Letter, ¶1278)

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Paragraph 149(1)(k) - Labour organizations

Cases

O'Brien v. The Queen, 85 DTC 5202, [1985] 1 CTC 285 (FCTD)

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Administrative Policy

5 February 1996 External T.I. 5-953282 -

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28 December 1995 T.I. 952934 (C.T.O. "Union Owning Shares")

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91 C.R. - Q.44

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 3 strike pay 19

Paragraph 149(1)(l) - Non-profit organizations

Cases

MNR v. Lakeview Golf Club Ltd., 52 DTC 1164 (Ex Ct)

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Gull Bay Development Corp. v. The Queen, 84 DTC 6040, [1984] CTC 159 (FCTD)

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Woodward's Pension Society v. The Minister of National Revenue, 62 DTC 1002, [1962] CTC 11, [1962] S.C.R. 224

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Minister of National Revenue v. St. Catharines Flying Training School Ltd., 55 DTC 1145, [1955] CTC 185, [1955] S.C.R. 738

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See Also

Coop publicitaire des concessionnaires Chrysler Jeep Dodge du Québec c. Agence du revenu du Québec, 2016 QCCQ 11252

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BBM Canada (formerly BBM Bureau of Measurement) v. The Queen, 2008 DTC 4129, 2008 TCC 341

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Words and Phrases
profits

Canadian Bar Insurance Association v. The Queen, 99 DTC 653 (TCC)

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Otineka Development Corp. Ltd. v. The Queen, 94 DTC 1234 (TCC)

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L.I.U.N.A. Local 527 Members' Training Trust Fund v. The Queen, 92 DTC 2365 (TCC)

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Words and Phrases
association

C. & E. Commrs v. Bell Concord Educational Trust Ltd., [1989] BTC 5061 (C.A.)

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Re Ogdensbury Bridge and Port Authority (1989), 56 DLR (4th) 56 (Ont HC)

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Re Kitchener-Waterloo Real Estate Board (1986), 56 OR (2d) 94 (HCJ)

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Regional Assessment Commisioner v. Caisse Populaire de Hearst, [1983] 1 S.C.R. 57, 143 DLR (3d) 590

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Administrative Policy

2016 Ruling 2015-0593841R3 - Sale of XXXXXXXXXX Club

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 149 - Subsection 149(5) no effect of s. 149(5)(e)(ii) on CDA amount 143

6 August 2015 External T.I. 2015-0565651E5 F - Reliquat dévolu à une administration municipale

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29 April 2015 External T.I. 2014-0532691E5 F - Vente – immeuble - syndicat copropriétaire

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation community of condominium owners is treated by the Civil Code as a legal person, and is a corporation 117
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) distribution of gain to members of a condominium syndicate gave rise to a shareholder benefit 75

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26 August 2014 External T.I. 2014-0528701E5 - Non-profit organization - Condominium

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30 May 2014 External T.I. 2014-0518841E5 - 149(1)(l) - Fundraising

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Words and Phrases
incidental
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Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business condominium solar revenue treated as members' income 231

Non-Profit Organization Risk Identification Project Report 17 February 2014

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23 September 2013 Internal T.I. 2012-0471531I7 F - Non-profit organization

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28 September 2012 External T.I. 2011-0429141E5 - NPO - Loan to Taxable Subsidiary

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27 September 2012 External T.I. 2011-0412961E5 - NPO and Taxable Subsidiary

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23 May 2012 External T.I. 2011-0418691E5 - 149(1)(l) - Lease or Sale of Lockers to Members

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30 March 2012 Internal T.I. 2011-0408851I7 - XXXXXXXXXX and 149(1)(l)

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29 March 2012 External T.I. 2010-0391311E5 F - OBNL, exploitation d'une entreprise

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28 March 2012 External T.I. 2011-0395201E5 - IT-496R

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27 November 2011 CTF National Conference CTF Roundtable, 2011-0426111C6 - 2011 CTF Question re NPOs

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23 June 2011 External T.I. 2011-0397881E5 - 149(1)(l) Entity - Use of Land by Shareholders

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) conferral on NPO member 63

28 November 2010 CTF Roundtable, 2010-0386301C6 - NPO Carrying on Business for Profit

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21 November 2001 External T.I. 2001-009528 -

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2 July 1998 T.I. 980455

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Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) 72

2 August 1995 T.I. 951683 (C.T.O. "NPO - Indian Forestry Corporation")

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Income Tax Technical News, No. 4, 20 February 1995

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25 July 1994 External T.I. 5-941379 -

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21 July 1994 T.I. 941422 (C.T.O. "Non-Profit Organization")

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23 March 1994 T.I. 933525 (C.T.O. "Non-Profit Organizations")

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26 August 1992 T.I. 921469 (April 1993 Access Letter, p. 150, ¶C144-207)

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9 March 1992 T.I. (Tax Window, No. 17, p. 23, ¶1790)

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14 February 1992 T.I. (Tax Window, No. 16, p. 22, ¶1749)

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23 October 1991 T.I. (Tax Window, No. 11, p. 12, ¶1533)

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6 September 1991 T.I. (Tax Window, No. 9, p. 21, ¶1448)

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17 July 1991 T.I. (Tax Window, No. 6, p. 14, ¶1358)

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15 November 1990 Memorandum (Tax Window, Prelim. No. 2, p. 15, ¶1079)

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23 February 1990 T.I. (July 1990 Access Letter, ¶1340)

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11 January 1990 Memorandum (June 1990 Access Letter, ¶1277)

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IT-83R3 "Non-Profit Organizations - Taxation of Income from Property"

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 149 - Subsection 149(5) 0

IT-496 "Non-Profit Organizations"

IT-409 "Winding-up of a Non-Profit Organization"

Articles

Joel Secter, "New Regime for Federal Not-For-Profits is Coming Soon", The Canadian Taxpayer, Vol xxxiii No. 14, 22 July 2011, p. 105: Overview of Canada Not-for-profit Corporations Act.

Knechtel, "Tax Treatment of Non-Profit Organizations", 1989 Conference Report, c. 35

Paragraph 149(1)(n) - Housing companies

Administrative Policy

17 August 2016 Internal T.I. 2016-0639251I7 - Capital Dividend Account and 149(1)(n)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (a) exempt low-rental housing corp can use a CDA 110
Tax Topics - Income Tax Act - Section 89 - Subsection 89(1.2) deemed 149(10) gain does not add to CDA before it disapppears under 89(1.2) 155

9 September 1996 Memorandum 962846 (C.T.O. "Limited Dividend Housing Company")

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29 July 1992 External T.I. 5-921729 -

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8 June 1992 T.I. 912877 (December 1992 Access Letter, p. 30, ¶C14-188)

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Paragraph 149(1)(o.2) - Idem [Pension corporations]

Subparagraph 149(1)(o.2)(ii)

Administrative Policy

5 March 2014 External T.I. 2013-0490641E5 - Pension Corp-Real Property Development

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14 January 2014 External T.I. 2012-0453871E5 F - Pension Real Estate Corporation

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2001 Ruling 2000-009708 -

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2001 Ruling 2000-007094 -

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Income Tax Technical News, No. 1, 22 July 1994

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18 February 1994 T.I. 940241 [taxable co-owner permitted, inventory development prohibited]

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93 C.R. - Q. 7

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25 November 1992 T.I. 921520 [development of capital property permitted]

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28 August 1992 T.I. (Tax Window, No. 23, p. 18, ¶2164)

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8 April 1992 T.I. (Tax Window, No. 18, p. 20, ¶1860)

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11 October 1991 T.I. (Tax Window, No. 11, p. 23, ¶1524)

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June 1990 T.I. (November 1990 Access Letter, ¶1532)

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Articles

Jack Silverson, Bill Corcoran, "Issues Affecting Investments by Canadian Pension Plans in Private Equity, Infrastructure and Real Estate in Canada, the USA and Europe", 2016 Conference Report (Canadian Tax Foundation),15:1-40

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

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 132 - Subsection 132(6) 0

Shafer, "Investments in Real Estate by Tax-Exempt Entities and Intermediaries", 1995 Corporate Management Tax Conference Report, c. 13.

Krasa, "Pension Real Estate Investment Corporations: Compliance Issues", 1995 Canadian Tax Journal, Vol. 43, No. 3, p. 610.

Clause 149(1)(o.2)(ii)(B)

Administrative Policy

21 December 2016 Internal T.I. 2013-0508321I7 - Pension Corporations - 149(1)(o.2)(iii)

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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)(iii) not generally precluded by the permitted investment rule from putting more than 10% of its assets in a single investment 208

Subparagraph 149(1)(o.2)(iii)

Administrative Policy

21 December 2016 Internal T.I. 2013-0508321I7 - Pension Corporations - 149(1)(o.2)(iii)

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10 May 2016 Internal T.I. 2016-0644761I7 - RPP borrowing

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 8502 - Paragraph 8502(i) pension plan could correct excess borrowing on a going-forward basis through assumption of the debt by a 149(1)(o.2)(ii) sub with plan guarantees 205

17 April 2014 External T.I. 2012-0461151E5 F - pension fund real estate

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14 August 2006 External T.I. 2005-0162911E5 - Subparagraph 149(1)(o.2)(iii) - Investments

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2002 Ruling 2001-010848 -

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2001 Ruling 2000-005546 -

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8 May 1997 External T.I. 5-963604 -

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15 February 1993 T.I. 9231345 [loan from pension fund shareholder]

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Articles

Jack Silverson, Bill Corcoran, "Issues Affecting Investments by Canadian Pension Plans in Private Equity, Infrastructure and Real Estate in Canada, the USA and Europe", 2016 Conference Report (Canadian Tax Foundation),15:1-40

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Words and Phrases
derived

Subparagraph 149(1)(o.2)(iv)

Administrative Policy

28 May 2015 External T.I. 2015-0582901E5 - 149(1)(o.2) Pension corporation

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Interpretation Act - Subsection 33(2) reference to beneficiaries includes single beneficiary 56

Paragraph 149(1)(o.4) - Master trusts

Administrative Policy

14 August 1992 T.I. (Tax Window, No. 23, p. 19, ¶2143)

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1 October 1991 T.I. (Tax Window, No. 10, p. 23, ¶1490)

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Articles

Krasa, "Income Tax Implications of Joint Investment by Pension Plans through a Private Pooled Fund Vehicle", 1997 Canadian Tax Journal, Vol. 45, No. 1, p. 1.

Paragraph 149(1)(t) - Farmers’ and fishermen’s insurer

Administrative Policy

28 June 2010 External T.I. 2009-0342671E5 - Paragraph 149(1)(t) - non-resident insurers

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21 December 1993 T.O. 933153 (C.T.O. "Unable to Rule/Question of Fact")

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29 January 1990 Memorandum (June 1990 Access Letter, ¶1279)

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Paragraph 149(1)(w)

Administrative Policy

28 June 2017 External T.I. 2017-0705431E5 - funds held in settlement account

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 150 - Subsection 150(1.1) - Paragraph 150(1.1)(b) - Subparagraph 150(1.1)(b)(i) class-action settlement fund was required to file T3 returns 179
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) litigation settlement trust with class action beneficiaries required to pay tax and file T3 returns 114

Subsection 149(1.2) - Income test

Administrative Policy

26 February 2014 External T.I. 2014-0518651E5 - 149(1)(c) - municipal corporation

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Subsection 149(3) - Application of s. (1)

Cases

Actra Fraternal Benefit Society v. Canada, 97 DTC 5243 (FCA)

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Subsection 149(4) - Idem [Application of s. (1)]

Cases

Lutheran Life Insurance Society of Canada v. The Queen, 91 DTC 5553 (FCTD)

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Subsection 149(5) - Exception re investment income of certain clubs

Cases

Point Grey Golf & Country Club v. Canada, 2000 DTC 6217 (FCA)

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See Also

Elmridge Country Club Inc. v. The Queen, 99 DTC 5127 (FCA)

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Words and Phrases
income from property

Administrative Policy

2016 Ruling 2015-0593841R3 - Sale of XXXXXXXXXX Club

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(l) CRA rules on the payment of a substantial capital dividend by a s. 149(1)(l) incorporated golf club 334

13 May 2014 Internal T.I. 2013-0499041I7 - Subparagraph 149(5)(e)(ii)

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12 April 2013 External T.I. 2012-0460901E5 - Capital Gain on Sale of Property by NPO

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2011 Ruling 2011-0400741R3 - Disposition of Property - XXXXXXXXXX Club

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9 July 1993 T.I. (Tax Window, No. 33, p. 7, ¶2642)

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4 September 1991 T.I. (Tax Window, No. 9, p. 15, ¶1439)

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23 February 1990 T.I. (July 1990 Access Letter, ¶1340)

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IT-83R3 "Non-Profit Organizations - Taxation of Income from Property"

Paragraph 149(5)(e)

Subparagraph 149(5)(e)(ii)

See Also

Mont-Bruno C.C. Inc. v. The Queen, 2016-1152(IT)G, 21 March 2017

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) Minister’s Reply lacked cogent factual allegations to justify a statute-barred assessment 396

Subsection 149(10) - Exempt corporations

Administrative Policy

6 March 2015 Internal T.I. 2014-0549761I7 - Internally generated goodwill & excluded property

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation unpurchased goodwill is taken into account 97
Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Excluded Property unpurchased goodwill is taken into account 193

2013 Ruling 2012-0463361R3 - Withdrawal of Ruling Request

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28 April 1994 Memorandum 933101 (C.T.O. "Terminal Losses & Loss of Tax-Exempt Status")

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22 November 1993 T.I. 932336 (C.T.O. "Non-Profit Organization - Terminal Losses")

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Brown, "The Transfer of Property on Death: Ownership, Control and Vesting", 1994 Canadian Tax Journal, Vol. 42, No. 6, p. 1449.

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