Subsection 248(1) - Definitions

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Cases

Canada v. Green, 2017 FCA 107

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 96 - Subsection 96(2.1) business losses of lower-tier LPs flowed through upper-tier partnership 526
Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(e) upper-tier LP not required to compute income and therefore not subject to s. 111(1)(e) 113
Tax Topics - Income Tax Act - 101-110 - Section 102 - Subsection 102(2) ITA recognizes 2-tier partnerships 66

Administrative Policy

21 November 2017 CTF Roundtable Q. 15, 2017-0724091C6 - Conversion from a US LP to an LLC

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f) an LLC resulting from a conversion from a US LLC has high inside and outside basis 244

2017 Ruling 2017-0687061R3 - Whether re-designation of LPUs is a disposition.

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