See Also
Granby Togs Ltd. v. M.N.R., 58 DTC 1082 (Ex. Ct.)
The Minister assessed the taxpayer for excess profits tax on the basis that it carried on a business formerly operated by a partnership, and that...
Lauger c. La Reine, 2008 DTC 3741, 2007 TCC 650 (Informal Procedure)
The performance by the first taxpayer of certain exercises on diskettes she was sent by a partnership in filling out a participation form in that...
Brillon v. The Queen, 2008 DTC 3445, 2006 TCC 76 (Informal Procedure)
The taxpayers were specified members of a partnership. First, with respect to subparagraph (b)(i) of the definition, they were not "actively...
Rouleau c. La Reine, 2007 DTC 1619, 2007 TCC 338 (Informal Procedure)
In finding that the taxpayer was a specified member of a partnership that had been formed only for the purposes of flowing R & D deductions out to...
Administrative Policy
11 October 2013 APFF Roundtable, 2013-0495861C6 F - Question 20 - APFF Round Table
In the course of a general discussion of negative ACB issues for a partner or limited partner, CRA stated (TaxInterpretations translation):
[A]...
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| Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.14) - Paragraph 40(3.14)(a) | not a limited partner if unlimited liability to third parties | 73 |
21 March 2011 External T.I. 2010-0375341E5 F - Associé déterminé
In the first scenario, Mr. S and SENC-V (a general partnership) hold interests in SENC-SV (another general partnership) of 90% and 10%,...
9 June 2010 External T.I. 2009-0342081E5 F - Associé déterminé
The sole trustee of Trust X is Mr. X, who conducts all the management of the business of a general partnership (“SENC”) of which Trust X is a...
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| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(1) | s. 104(1) imputes the activities of the trustee to the trust for “specified member” purposes | 124 |
30 October 2002 External T.I. 2002-0126045 F - TRANSFERT A UN MINEUR
Regarding whether two minor children of the taxpayer were not “specified members” of a partnership between them, so that s. 96(1.8) would...
13 March 1996 APFF Roundtable Q. 24, 9616880 - CALGARY TAX SERVICES ROUND TABLE - QUESTION 24
A partner's participation in a management committee that sets budgets and makes decisions on an exception basis only (e.g.,where the decision in...
1995 International Fiscal Association Conference, Q. 8 (C.T.O. "6363-1 Foreign Affiliate - Specified Member of Partnership")
"A person is actively engaged in the business of a partnership for the purposes of the definition of 'specified member' in subsection 248(1) of...
1993 Administrative Letter 9335986 F - Partnership - Specified Member
Re criteria for determining whether a partner is a specified member.
1992 A.P.F.F. Annual Conference, Q. 17 (January - February 1993 Access Letter, p. 56)
Partners whose only involvement in the partnership business is to answer surveys and to meet from time to time with persons in charge of the SR&ED...
IT-73R4 "The Small Business Deduction - Income from an Active Business, a Specified Investment Business and a Personal Services Business".
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| Tax Topics - Income Tax Act - Section 125.3 - Subsection 125.3(4) | 0 |