Section 34.2

Old 34.2

Administrative Policy

19 February 1997 T.I. 962474

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20 February 1997 Memorandum 963707

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Subsection 34.2(1) - Definitions

Adjusted Stub Period Accrual Income

Administrative Policy

12 April 2012 External T.I. 2012-0436121E5 - ASPA, QTI and significant interest

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8 February 2012 External T.I. 2011-0425411E5 - Change in fiscal period & transitional reserve

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Articles

Janette Pantry, Robyn Campbell, "Partnerships and ASPA on Acquisition of Control", Canadian Tax Highlights, Vol. 24, No. 10, October 2016, p. 3

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Shane Onufrechuk, Warren Pashkowick, "Tax Considerations of Major Construction Projects", 2014 Conference Report, Canadian Tax Foundation, 10:1-35.

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Subsection 34.2(2) - Income inclusion — adjusted stub period accrual

Administrative Policy

10 May 2017 External T.I. 2017-0687051E5 F - Addition to ACB of a partnership interest

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(i) no s. 53(1)(e) addition for s. 34.2(2) stub period income inclusion 116

4 November 2014 External T.I. 2014-0539191E5 - ASPA under 34.2(2)

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Subsection 34.2(11) - Transitional reserve

Administrative Policy

2015 Ruling 2015-0601441R3 - XXXXXXXXXX Partnership - winding up

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) 98(5) wind-up through s. 85 transfer of partnership interest of one partner to the other and preceded by debt assumptions 272
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(ii) interest deductible following assumption of interest-bearing internal debt on s. 98(5) wind-up 279
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) continued availability of s. 20(1)(m) reserve following s. 98(5) wind-up 266
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(n) flow-through of s. 20(1)(n) reserve on s. 98(5) wind-up 262
Tax Topics - Income Tax Act - Section 20 - Subsection 20(24) s. 20(24) election on s. 98(5) wind-up 280
Tax Topics - Income Tax Act - Section 18 - Subsection 18(9) s. 18(9) deduction claimable by transferee former partner following s. 98(5) wind-up 216
Tax Topics - Income Tax Act - Section 147.2 - Subsection 147.2(8) s. 147.2 continuity following s. 98(5) wind-up 336
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(i) no income inclusion on assumption on s. 98(5) wind-up of DSUs and RSUs 329
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Salary Deferral Arrangements - Paragraph (k) no income on RSU/DSU assumption 20

9 April 2014 External T.I. 2013-0503421E5 F - Transitional reserve

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14 February 2014 External T.I. 2012-0454481E5 F - Safe Income

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) not claiming s. 34.2(11) transitional reserve to increase SIOH 357
Tax Topics - Income Tax Act - Section 55 - Subsection 55(5) - Paragraph 55(5)(c) no departures permitted from s. 34.2 adjustments 180

Subsection 34.2(13) - No reserve

Paragraph 34.2(13)(a)

Administrative Policy

4 December 2013 External T.I. 2013-0499681E5 - Transitional reserve - tiered partnership

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Subsection 34.2(14) - Deemed partner

Administrative Policy

2014 Ruling 2013-0516071R3 - Reorganization

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a) transfer of already-earned profits to Lossco by transfer of LP units with income allocation at LP year end 278
Tax Topics - Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(f) transfer of profitable LP to Lossco followed by allocation of previously-earned profits of LP to Lossco 87