Subsection 43(1) - General rule for part dispositions
Administrative Policy
11 October 2019 APFF Roundtable Q. 3, 2019-0812621C6 F - Changement d’usage-impact sur l’exemption pour résidence principale
After Monsieur acquired a duplex in January 2011, he used the two units for renting to a third party and as his personal residence, respectively....
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|---|---|---|
| Tax Topics - Income Tax Act - Section 54 - Principal Residence - Paragraph (c) | reporting of principal residence exemption when the residence had been expanded from 1 to 2 duplex units | 278 |
| Tax Topics - Income Tax Act - Section 45 - Subsection 45(3) | method for making s. 45(3) election where conersion of duplex | 181 |
S3-F4-C1 - General Discussion of Capital Cost Allowance
Non-pro-rata apportionment
1.77 … [T]he pro rata apportionment of the capital cost of a depreciable property would not be reasonable in all...
1 October 2013 External T.I. 2013-0491571E5 - Partial disposition of partnership interest - ACB
Where a partner disposes of some of its units of a partnership during the year, is there an ACB adjustment for the entire amount of the income...
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| Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(i) | all units are single property/entire gain allocated to remaining units | 177 |
18 June 2012 External T.I. 2012-0446131E5 - Meaning of "at that time" in 43(1)
"[T[he phrase 'at that time' as used in subsection 43(1) of the Act, would, in our view, refer to the time immediately before the particular...
8 October 2010 Roundtable, 2010-0373461C6 F - Retrait d'une société de personnes
Before going on to find that there was a pro rata recognition of capital gain when 20% of a partner’s units were redeemed, CRA stated:
[A]ll the...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 40 - Subsection 40(3) | negative ACB realized pro rata as units are redeemed | 51 |
| Tax Topics - Income Tax Act - Section 100 - Subsection 100(2) | negative ACB realized pro rata under s. 100(2) as portion of the units are redeemed each year | 201 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property | partnership unit is not separate property from other units | 57 |
8 September 2009 External T.I. 2008-0299771E5 F - Gain on Disposition of Debt
Over the years, A made advances (the "Debt") to Aco which it wholly owned, and then sold all the shares of A to an arm’s length purchaser, as...
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| Tax Topics - Income Tax Act - Section 9 - Computation of Profit | partial repayment of low-cost debt generates business income if held on income account | 89 |
29 July 2009 External T.I. 2008-0297011E5 F - Conversion de participations dans une SNC
A partnership has several members, some of whom hold partnership interests which participate in both income and capital of the partnership. The...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | no disposition if new partnerships interests exchanged for old interests that in totality are not substantially distinguishable | 213 |
| Tax Topics - Income Tax Act - Section 97 - Subsection 97(2) | s. 97(2) rollover not available if new partnerships interests exchanged for old interests are not in totality substantially distinguishable | 274 |
| Tax Topics - Income Tax Act - Section 96 - Subsection 96(1.01) | s. 96(1.01) inapplicable where only income interest and not capital interest disposed of | 139 |
Rulings Directorate Discussion and Position Paper on Motion Picture Films and Video Tapes as Tax Shelters, Version 29/3/93 930501 (C.T.O. "Motion Picture Films - C.C.A.")
In an arrangement in which a creditor is entitled to all the income and losses following conversion of its loan into an interest in a film...
4 August 1999 External T.I. 9918345 - GAIN ON DISPOSITION OF DEBT OBLIGATIONS
What are the tax implications to a creditor which receives a payment on account of a debt obligation’s principal amount that is greater than the...
4 September 1991 T.I. (Tax Window, No. 9, p. 20, ¶1445)
Where there is a partial repayment of a debt acquired by a taxpayer on capital account and at a discount, the taxpayer must use the part...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Computation of Profit | 52 |
IT-373R "Farm Woodlots and Tree Farms"
Amounts received for permitting other persons to remove standing trees from a woodlot will normally reduce the adjusted cost base of the whole...
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| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Commodities, and commodities futures and derivatives | 31 |
IT-264R "Part Dispositions"
Easements
2. The granting of an easement or a public right of way is a disposition of a part of the property in respect of which it is granted....