Subsection 189(1) - Tax regarding non-qualified investment
Administrative Policy
5 December 2019 Internal T.I. 2017-0683831I7 - Prescribed Rates and Undue Benefits
Headquarters rejected the proposition that where a registered charity that is a private foundation makes a loan at the prescribed rate of interest...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 188.1 - Subsection 188.1(4) | the making of a loan at the prescribed rate under s. 189(1) does not prelude a penalty under s. 188.1(4) | 179 |
28 July 1992 Memorandum 921859 (April 1993 Access Letter, p. 151, ¶C180-136)
A taxpayer is not considered to have "paid" interest on a loan owing by him to a charitable foundation by virtue only of journal entries being...
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|---|---|---|
| Tax Topics - General Concepts - Payment & Receipt | 37 | |
| Tax Topics - Income Tax Regulations - Regulation 2900 - Subsection 2900(2) | 68 |
Subsection 189(3) - Share deemed to be debt
Administrative Policy
9 May 1994 External T.I. 9407105 - LIABILITY FOR PART V TAX
A deemed dividend arising on the redemption of shares gifted to a private foundation will be deemed to be interest for purposes of s. 189(1) by...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 149.1 - Subsection 149.1(1) - Disbursement Quota | 48 |
28 January 1994 External T.I. 9401445 - PRIVATE FOUNDATIONS
Where an individual gifts shares of a corporation to a registered charity that is a private foundation, the cost amount of the shares to the...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 149.1 - Subsection 149.1(12) - Paragraph 149.1(12)(a) | 163 |
June 1990 Meeting of Alberta Institute of Chartered Accountants (November 1990 Access Letter, ¶1499, Q. 3)
Where an individual rolls the shares of Opco under s. 85(1) to a newly-incorporated private foundation, the cost amount of the shares to the...
Subsection 189(6) - Taxpayer to file return and pay tax
Administrative Policy
25 August 1994 Internal T.I. 9421756 - PENALTY - FAILURE TO FILE T2140
A person can be assessed a penalty under s. 162(1) for failure to file a return as required by s. 189 in respect of a non-qualified investment...
Subsection 189(7) - Minister may assess
Cases
Humane Society of Canada for the Protection of Animals and the Environment v. Canada (National Revenue), 2015 FCA 178
The appellant appealed a CRA decision to revoke its registration, which was made on grounds which included reference to substantial amounts paid...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 168 - Subsection 168(1) - Paragraph 168(1)(e) | personal expenses were intermingled in accounting records | 238 |
| Tax Topics - Income Tax Act - Section 172 - Subsection 172(3) - Paragraph 172(3)(a.1) | no implied procedural rules in s. 172(3)(a.1) | 155 |