Section 249.1

Subsection 249.1(1)

See Also

Les Développements Iberville Ltée v. Agence du Revenu du Québec, 2018 QCCA 1886 (Quebec Court of Appeal)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) abuse to use rollover provisions to avoid rather than defer tax 633
Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) abuse of Quebec equivalents of ss. 85(1) and 97(2) to avoid (rather than defer) tax 390
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate property bifurcated between capital and income portion on acquisition 94
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense improvements to leased retail premises were not demonstrated to be made only at tenants’ requests 91
Tax Topics - Income Tax Regulations - Regulation 402 - Subsection 402(6) purpose of inter-provincial allocation rules is for 109% of income to be allocated and taxed 510

Administrative Policy

15 August 2012 External T.I. 2012-0438481E5 - Change of Fiscal Period Year-End

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11 September 1996 T.I. 960940 (C.T.O "Fiscal Period - Bare Trust")

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See also

Paragraph 249.1(1)(c)

Administrative Policy

18 August 2014 External T.I. 2014-0528001E5 - Fiscal period of a partnership

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 249.1 - Subsection 249.1(4) corporate sub of upper-tier partnership is member of lower-tier partnership 97

28 August 2012 External T.I. 2012-0454811E5 - Multi-tiered joint ventures

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13 March 2012 External T.I. 2012-0432111E5 - Revised joint venture policy

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Subsection 249.1(2) - Not a member of a partnership

Administrative Policy

28 February 2012 External T.I. 2011-0424191E5 F - Fiscal period of a partnership

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Words and Phrases
share of income

Subsection 249.1(4) - Alternative method

Administrative Policy

20 February 2017 External T.I. 2014-0534341E5 F - Partnership change of fiscal period

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 249.1 - Subsection 249.1(7) requirement for serious commercial reason for change in non-calendar year end 78

18 August 2014 External T.I. 2014-0528001E5 - Fiscal period of a partnership

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 249.1 - Subsection 249.1(1) - Paragraph 249.1(1)(c) corporate sub of upper-tier partnership is member of lower-tier partnership 123

5 June 2003 External T.I. 2002-017848 -

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11 September 1996 T.I. 961057 (C.T.O "Fiscal Period - Co-Ownership")

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Subsection 249.1(7) - Change of fiscal period

Administrative Policy

2017 Ruling 2016-0674681R3 - Sequential Split-Up Butterfly

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Distribution sequential split-up butterfly with 1% tolerance, triggering of capital gains to generate CDA and RDTOH, and year end change to accommodate RDTOH division 656
Tax Topics - Income Tax Act - Section 129 - Subsection 129(1) capital gain deliberately triggered to generate CDA and RDTOH addition and year end change granted to isolate dividend refund 499
Tax Topics - Income Tax Act - Section 55 - Subsection 55(3.1) - Paragraph 55(3.1)(a) sale of securities for cash proceeds that are reinvested, and tendering shares for shares of offeror 56

20 February 2017 External T.I. 2014-0534341E5 F - Partnership change of fiscal period

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 249.1 - Subsection 249.1(4) a partnership of individuals can change with CRA’s permission to a different non-calendar year end 244

2015 Ruling 2015-0605901R3 F - Présomption de gain en capital

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 55 - Subsection 55(3.01) - Paragraph 55(3.01)(g) separation of real estate assets beneath new holdco formed by unrelated shareholders 512
Tax Topics - Income Tax Act - Section 55 - Subsection 55(3) - Paragraph 55(3)(a) - Subparagraph 55(3)(a)(ii) spin-off of real estate beneath new common holdoc of unrelated shareholders 105
Tax Topics - Income Tax Act - Section 186 - Subsection 186(1) - Paragraph 186(1)(b) year end selection to avoid Pt. IV circularity 91

9 December 2014 External T.I. 2014-0529311E5 - Change the fiscal period end of a partnership

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Subsection 249.1(8) - Single-tier fiscal period alignment

Administrative Policy

8 March 2012 External T.I. 2011-0429481E5 - Single-tier alignment conditions

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Subsection 249.1(10) - Conditions to align a partnership fiscal period

Administrative Policy

24 April 2012 External T.I. 2012-0444451E5 - Multi-tier alignment election

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