Subsection 149(1) - Miscellaneous exemptions
Paragraph 149(1)(a) - Employees of a country other than Canada
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 -
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 -
92 C.R. - Q.36
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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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(l) | 98 | |
| Tax Topics - Income Tax Act - Section 9 - Agency - Agency | 177 | |
| Tax Topics - Statutory Interpretation - Similar Statutes | 84 |
Administrative Policy
6 July 2001 External T.I. 2001-008157 -
13 July 1995 External T.I. 5-950326 -
6 July 1995 External T.I. 3-943135 -
21 June 1995 External T.I. 5-950988 -
29 March 1994 T.I. 940775 (C.T.O. "Right of Redemption")
11 January 1993 Memorandum (Tax Window, No. 28, p. 19, ¶2387)
Articles
J. Peter Ranson, "The Evolution of Aboriginal Tax Exemptions: The Past, the Present and the Future", 2005 Conference Report, c. 24.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Indian Act - Section 87 | 0 |
Paragraph 149(1)(d.3) - 90% owned corporations
Paragraph 149(1)(d.4) - Combined ownership
Paragraph 149(1)(d.5) - Income within boundaries of entities
See Also
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 |
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
Paragraph 149(1)(f) - Registered charities
Cases
Canada v. Nova Scotia Power Inc., 2003 DTC 5090, 2003 FCA 33
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Interpretation Act - Section 17 | 236 |
Paragraph 149(1)(i) - Certain housing corporations
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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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 37 - Subsection 37(7) - Approved | 20 |
19 October 1993 Memorandum 932981 (C.T.O. "Approved for Scientific Research")
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)
Paragraph 149(1)(k) - Labour organizations
Cases
O'Brien v. The Queen, 85 DTC 5202, [1985] 1 CTC 285 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc. | 40 |
Administrative Policy
5 February 1996 External T.I. 5-953282 -
28 December 1995 T.I. 952934 (C.T.O. "Union Owning Shares")
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)
Gull Bay Development Corp. v. The Queen, 84 DTC 6040, [1984] CTC 159 (FCTD)
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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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Nature of Income | 77 |
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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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 9 - Nature of Income | 78 |
See Also
Coop publicitaire des concessionnaires Chrysler Jeep Dodge du Québec c. Agence du revenu du Québec, 2016 QCCQ 11252
BBM Canada (formerly BBM Bureau of Measurement) v. The Queen, 2008 DTC 4129, 2008 TCC 341
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Canadian Bar Insurance Association v. The Queen, 99 DTC 653 (TCC)
Otineka Development Corp. Ltd. v. The Queen, 94 DTC 1234 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(d) | 113 | |
| Tax Topics - Income Tax Act - Section 9 - Agency - Agency | 177 | |
| Tax Topics - Statutory Interpretation - Similar Statutes | 84 |
L.I.U.N.A. Local 527 Members' Training Trust Fund v. The Queen, 92 DTC 2365 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 149.1 - Subsection 149.1(1) - Charitable Organization | 45 |
C. & E. Commrs v. Bell Concord Educational Trust Ltd., [1989] BTC 5061 (C.A.)
Re Ogdensbury Bridge and Port Authority (1989), 56 DLR (4th) 56 (Ont HC)
Re Kitchener-Waterloo Real Estate Board (1986), 56 OR (2d) 94 (HCJ)
Administrative Policy
2016 Ruling 2015-0593841R3 - Sale of XXXXXXXXXX Club
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| 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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| Locations of other summaries | Wordcount | |
|---|---|---|
| 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 |
4 March 2015 External T.I. 2014-0537941E5 - Non-Profit Organization fibre-optic cable
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11 September 2014 External T.I. 2014-0540031E5 - Community Contribution Company (C3)
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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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18 August 2014 External T.I. 2014-0528171E5 - Condominium Corporations and 149(1)(l)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| 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
23 September 2013 Internal T.I. 2012-0471531I7 F - Non-profit organization
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12 August 2013 External T.I. 2012-0468581E5 - Condo corp sale or rental of caretaker suite
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2 August 2013 External T.I. 2013-0475041E5 - NPO - rental income
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2 July 2013 External T.I. 2012-0454251E5 - 149(1)(l) donations to capital fund
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21 November 2012 Internal T.I. 2012-055501I7 -
20 November 2012 Internal T.I. 2012-0439951I7 - NPO Project
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16 October 2012 External T.I. 2012-0448531E5 - XXXXXXXXXX update on NPO audit project
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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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20 June 2012 Internal T.I. 2011-0426231I7 -
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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12 March 2012 Internal T.I. 2012-0404671I7 -
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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20 February 2012 Internal T.I. 2011-0429471I7 F - OBNL et profits accessoires
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20 February 2012 Internal T.I. 2011-0429461I7 F - OBNL et profits accessoires
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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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| Locations of other summaries | Wordcount | |
|---|---|---|
| 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 -
2 July 1998 T.I. 980455
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | 72 |
2 August 1995 T.I. 951683 (C.T.O. "NPO - Indian Forestry Corporation")
Income Tax Technical News, No. 4, 20 February 1995
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 160 - Subsection 160(1) | 58 | |
| Tax Topics - Treaties - Income Tax Conventions - Article 13 | 44 |
25 July 1994 External T.I. 5-941379 -
21 July 1994 T.I. 941422 (C.T.O. "Non-Profit Organization")
10 July 1994 External T.I. 5-941497 -
27 June 1994 External T.I. 5-940814 -
23 March 1994 T.I. 933525 (C.T.O. "Non-Profit Organizations")
26 August 1992 T.I. 921469 (April 1993 Access Letter, p. 150, ¶C144-207)
9 March 1992 T.I. (Tax Window, No. 17, p. 23, ¶1790)
14 February 1992 T.I. (Tax Window, No. 16, p. 22, ¶1749)
23 October 1991 T.I. (Tax Window, No. 11, p. 12, ¶1533)
6 September 1991 T.I. (Tax Window, No. 9, p. 21, ¶1448)
17 July 1991 T.I. (Tax Window, No. 6, p. 14, ¶1358)
15 November 1990 Memorandum (Tax Window, Prelim. No. 2, p. 15, ¶1079)
23 February 1990 T.I. (July 1990 Access Letter, ¶1340)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 149 - Subsection 149(5) | 8 | |
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | 28 |
11 January 1990 Memorandum (June 1990 Access Letter, ¶1277)
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")
29 July 1992 External T.I. 5-921729 -
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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26 June 2002 External T.I. 2002-013488 -
2001 Ruling 2000-009708 -
2001 Ruling 2000-007094 -
Income Tax Technical News, No. 1, 22 July 1994
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(b) | 65 | |
| Tax Topics - Income Tax Act - Section 9 - Timing | 27 |
18 February 1994 T.I. 940241 [taxable co-owner permitted, inventory development prohibited]
93 C.R. - Q. 7
25 November 1992 T.I. 921520 [development of capital property permitted]
28 August 1992 T.I. (Tax Window, No. 23, p. 18, ¶2164)
8 April 1992 T.I. (Tax Window, No. 18, p. 20, ¶1860)
11 October 1991 T.I. (Tax Window, No. 11, p. 23, ¶1524)
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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| 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) | 990 | |
| Tax Topics - Treaties - Multilateral Instrument - Article 7 | 161 |
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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| 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)(ii) - Clause 149(1)(o.2)(ii)(B) | 10% PBSA limitation applied only at pension fund level | 100 |
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 -
2001 Ruling 2000-005546 -
8 May 1997 External T.I. 5-963604 -
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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| 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)(ii) | 409 | |
| Tax Topics - Treaties - Multilateral Instrument - Article 7 | 161 |
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)
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.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 5000 - Subsection 5000(7) - Pooled Fund Trust | 0 |
Paragraph 149(1)(t) - Farmers’ and fishermen’s insurer
Administrative Policy
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
Subsection 149(3) - Application of s. (1)
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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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 138 - Subsection 138(3) - Paragraph 138(3)(a) | 263 |
Subsection 149(5) - Exception re investment income of certain clubs
Cases
See Also
Elmridge Country Club Inc. v. The Queen, 99 DTC 5127 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | 45 |
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)
4 September 1991 T.I. (Tax Window, No. 9, p. 15, ¶1439)
23 February 1990 T.I. (July 1990 Access Letter, ¶1340)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(l) | 101 | |
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | 28 |
IT-83R3 "Non-Profit Organizations - Taxation of Income from Property"
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(l) | 0 |
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 | |
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| 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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