Section 206

Paragraph 206(1)(c)

Administrative Policy

20 June 1996 TI 96122

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12 April 1995 External T.I. 9501555 - WARRANTS AS FOREIGN PROPERTY FOR RRSP

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30 August 1994 External T.I. 9420165 - FOREIGN PROPERTY-RPP

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22 June 1994 External T.I. 9413475 - COMMODITY FUTURES CONTRACTS

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 132 - Subsection 132(6) commodity futures contracts 13

24 February 1994 External T.I. 9401775 - FOREIGN CURRENCY HELD BY REGISTERED PENSION

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Paragraph 206(1)(d.1)

Administrative Policy

16 March 2000 External T.I. 2000-0014105 - EXCHANGEABLE SHARE AS FOREIGN PROPERTY

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11 October 1994 Internal T.I. 9417147 - RRSP QUALIFIED INVESTMENT IN DEBENTURES

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26 August 1994 External T.I. 9421335 - FOREIGN PROPERTY

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7 September 1989 TI 5-8316

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86 C.R. - Q.19

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 94.1 - Subsection 94.1(1) 18

Paragraph 206(1)(f)

Administrative Policy

6 September 1995 External T.I. 9523295 - U.S. OPTIONS QUALIFIED PROPERTY

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Articles

Woods, "Dividend Access Shares", 1991 Canadian Tax Journal, p. 709.

Paragraph 206(1)(g)

Administrative Policy

2004 Ruling 2004-0060891R3 - Linked notes - foreign property rules

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Paragraph 206(1)(h)

See Also

Henderson Estate v. M.N.R, 73 DTC 5471, [1973] CTC 636 (FCTD), aff'd 75 D.TC 5332, [1975] C.TC 485 (FCA)

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Administrative Policy

2002 Ruling 2002-0134003 - FOREIGN PROPERTY DEBTS OF A TRUST

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2001 Ruling 2001-0076453 - Pre-paid Forward Contract - Mimic - Foreign

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1999 Ruling 9923043 - MUTUAL FUND TRUST USING DERIVATIVES

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1999 Ruling 9918323 - XXXXXXXXXX Business of a Commercial Trust

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 108 - Subsection 108(2) - Paragraph 108(2)(a) MFT's units are redeemable in cash for lesser of 90% of 10-day trading average and spot, with redemptions in excess of cash cap satisfied with pro rata units and notes of sub trust 270

30 November 1997 Ruling 982725A - DEBT OBLIGATION - FOREIGN PROPERTY

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30 November 1995 Ruling 9609943 - FORWARD CONTRACT, MARKETABLE SECURITY

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18 April 1995 External T.I. 9500895 - POOLED FUND TRUSTS

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27 March 1995 External T.I. 9501185 F - QUALIFIED INVESTMENTS IN AN RRSP

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10 March 1995 External T.I. 9500835 - QUALIFIED INVESTMENTS & FOREIGN PROPERTY

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17 June 1993 TI (Tax Window, No. 32, p. 19, ¶2618)

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17 June 1993 TI (Tax Window, No. 32, p. 19, ¶2617)

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23 May 1991 TI (Tax Window, No. 3, p. 31, ¶1264)

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88 CR - Q.59

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Paragraph 206(1)(i)

Administrative Policy

1999 Ruling 9928313 - CLONE FUND - ARE UNITS FOREIGN PROPERTY

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1999 Ruling 9915413 - DERIVITIVES TO MIMIC FOREIGN MUTUAL FUNDS

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16 August 1994 External T.I. 9418025 - SEGREGATED FUNDS AS TRUSTS FOR ALL OF ACT

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11 February 1994 Internal T.I. 9314227 - HAA 7234-1 SEG FUND IS A FROEIGN PROPERTY (TRUST)

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Paragraph 206(1.1)(d)

Administrative Policy

2003 Ruling 2003-0014843 - DEBT OF PARTNERSHIP FOREIGN PROPERTY

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12 September 2002 External T.I. 2002-0140935 - FOREIGN PROPERTY - SUBSTANTIAL CDN. PRESENCE

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2000 Ruling 1999-0012793 - FOREIGN PROPERTY TAX

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15 July 1997 External T.I. 9716045 - SUBSTANTIAL CANADIAN PRESENCE

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15 May 1997 External T.I. 9710025 - WHETHER "INCORPORATED" IN YEAR AMALGAMATED

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10 April 1997 External T.I. 9703265 - SUBSTANTIAL CANADIAN PRESENCE

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13 February 1997 External T.I. 9701235 - SUBSTANTIAL CANADIAN PRESENCE

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15 October 1996 External T.I. 9634015 - SUBSTANTIAL CANADIAN PRESENCE

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17 October 1996 External T.I. 9634235 - SUBSTANTIAL CANADIAN PRESENCE

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15 October 1996 Administrative Letter 963382A - SERVICES OF OTHER INDIVIDUALS

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Subsection 206(2) - Amount of tax payable

Administrative Policy

2003 Ruling 2003-0041823 - FOREIGN PROPERTY PENSION CORPORATIONS

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7 January 2003 External T.I. 2002-0159065 - SWAP AGREEMENT FOREIGN PROPERTY

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29 January 2002 External T.I. 2001-0105795 - REGISTERED PLANS FOREIGN PROPERTY

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29 October 2001 External T.I. 2001-0099135 - RRSP FOREIGN PROPERTY TAX

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31 May 1999 External T.I. 9906745 - FOREIGN PROPERTY - COST AMOUNT

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17 February 1999 External T.I. 9832275 - RRSP, WRITE-OFF MORTGAGE

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8 June 1998 External T.I. 9806285 - RRSP - FOREIGN PROPERTY & REINVESTED EARNINGS

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30 November 1995 Ruling 9609943 - FORWARD CONTRACT, MARKETABLE SECURITY

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28 April 1995 External T.I. 9501905 - TRANSFERS TO AND FROM REGISTERED PLANS

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10 March 1992 Memorandum (Tax Window, No. 17, p. 18, ¶1799)

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19 June 1990 TI (November 1990 Access Letter, ¶1533)

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11 July 1989 TI (Dec. 89 Access Letter, ¶1063)

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Finance

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Subsection 206(2.1)

Administrative Policy

2004 Ruling 2003-0052061R3 - 259(3) Election - 149(1)(o.2) Pension Corporation

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Subsection 206(4) - Payment of amount collected to RDSP

Administrative Policy

Tax Professionals Mini Round Table - Vancouver - Q. 6 (March 1993 Access Letter, p. 103)

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Articles

W. Holmes, M. Colborne, "Foreign Property Rules and Transfer of Assets", Taxation of Executive Compensation and Retirement, Vol. 9, No. 8, April 1998, p. 135

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