See Also
Vinet v. Sous-ministre du Revenu du Québec, 2017 QCCQ 3957, aff'd 2019 QCCQ 574
An individual, who was the sole limited partner of a Quebec limited partnership (“SEC”) that owned and operated multiple farms, and the...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 96 - Subsection 96(2.4) - Paragraph 96(2.4)(a) | managerial actions of an individual limited partner were qua officer of the GP, so that he was a limited partner for tax purposes | 356 |
Major v. Brodie & Anor, [1998] BTC 141 (Ch. D)
The taxpayers used borrowed money to make a contribution of capital to a partnership (Skeldon Estates) which was a member of a second partnership...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 102 - Subsection 102(2) | top tier partners are lower tier partnership members | 242 |
| Tax Topics - Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(f) | 242 | |
| Tax Topics - Statutory Interpretation - Provincial Law | 97 |
Administrative Policy
2018 Ruling 2017-0723421R3 - Creation of a new Mutual Fund Trust
The Trust, which will be settled by an officer of its Manager, will invest principally in the limited partner units (Class A units) of a limited...
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|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 108 - Subsection 108(2) - Paragraph 108(2)(a) | non-listed MFT can redeem with notes issued by vacuous sub trust, or suspend redemptions for 1 year | 528 |
2013 Ruling 2013-0487911R3 - Mortgage Investment Corporation
Background
Opco, which qualifies as a MIC under s. 130.1(6), acquired real property (the Property) on foreclosing on a mortgage. Parent1 together...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 130.1 - Subsection 130.1(6) | carrying on non-qualifying activities through subsidiary LP; GP held by relative of patriarch | 208 |
17 March 2003 External T.I. 2001-0095675 - Unit Trust investing in a limited partnership
As a result of the introduction of s. 253.1, the mere ownership of an interest in a limited partnership will not jeopardize the qualification of a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 108 - Subsection 108(2) - Paragraph 108(2)(b) | partnership look-through for s. 108(2)(b)(iii) to (v) purposes | 271 |
| Tax Topics - Income Tax Act - Section 96 | Ontario partnership debt owing to limited partner respected | 309 |
2001 Ruling 2001-0070943 - PARTNERSHIP INTEREST PENSION CORP.
Based on revised explanatory notes issued on June 16, 2000, the Agency ruled that the acquisition of limited partnership units in a limited...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b) | exercise price respected as the proceeds of property subject to NAL option | 57 |
| Tax Topics - Income Tax Act - Section 97 - Subsection 97(2) | question of fact whether post-drop-down loan is boot | 81 |
Subsection 253.1(2)
Administrative Policy
Guidance on the income tax measures to support journalism CRA Webpage 23 December 2019
Related business exception must be complied with if not within s. 253,1(2)
5.14. An RJO can hold an interest in a partnership and it will not be...