Section 253.1

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Qualified Canadian Journalism Organization - Paragraph (b) 146
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Qualified Canadian Journalism Organization - Paragraph (a) - Subparagraph (a)(v) 414
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Qualified Canadian Journalism Organization - Paragraph (a) - Subparagraph (a)(vi) 91
Tax Topics - Income Tax Act - Section 125.6 - Subsection 125.6(1) - Qualifying Journalism Organization 335
Tax Topics - Income Tax Act - Section 125.6 - Subsection 125.6(1) - Qualifying Labour Expenditure 365
Tax Topics - Income Tax Act - Section 125.6 - Subsection 125.6(1) - Eligible Newsroom Employee 199
Tax Topics - Income Tax Act - Section 125.6 - Subsection 125.6(2) 167
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) 258
Tax Topics - Income Tax Act - Section 118.02 - Subsection 118.02(1) - Qualifying Subscription Expense 112
Tax Topics - Income Tax Act - Section 118.02 - Subsection 118.02(2) 72
Tax Topics - Income Tax Act - Section 149.1 - Subsection 149.1(1) - Qualifying Journalism Organization - Paragraph (b) 188
Tax Topics - Income Tax Act - Section 149.1 - Subsection 149.1(1) - Qualifying Journalism Organization - Paragraph (c) 270
Tax Topics - Income Tax Act - Section 149.1 - Subsection 149.1(1) - Qualifying Journalism Organization - Paragraph (f) - Subparagraph (f)(iii) 143
Tax Topics - Income Tax Act - Section 149.1 - Subsection 149.1(1) - Qualifying Journalism Organization 175
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Registered Journalism Organization 225