Section 53

Subsection 53(1) - Adjustments to cost base

Paragraph 53(1)(b)

Administrative Policy

16 November 2011 External T.I. 2011-0423861E5 F - paragraph 53(1)b)

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Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (a) - Subparagraph (a)(i) - Clause (a)(i)A) example of capital gain for CDA purposes being less than the s. 40 capital gain 511

Subparagraph 53(1)(b)(ii)

Administrative Policy

27 November 2018 CTF Roundtable Q. 2, 2018-0780071C6 - Impact of 55(2) deeming rules

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Tax Topics - Income Tax Act - Section 52 - Subsection 52(2) property dividended has cost equal to FMV where subject to s. 55(2) 104
Tax Topics - Income Tax Act - Section 52 - Subsection 52(3) cost under s. 52(3) for stock dividend amount to which s. 55(2) applied 69
Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (a) - Subparagraph (a)(i) 53(1)(b)(ii) and 52(3)(a) exclusion limited to where 55(2) did not apply to the stock dividend or PUC increase 70
Tax Topics - Income Tax Act - Section 112 - Subsection 112(3) - Paragraph 112(3)(b) - Subparagraph 112(3)(b)(i) stop-loss rule does not apply to the extent of the application of s. 55(2) 83

Articles

Rick McLean, Jeff Oldewening, Jonas Lau, "Capital Gains Stripping and Surplus Stripping", 2017 Annual CTF Conference draft paper

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Paragraph 53(1)(c)

See Also

Burman v. The Queen, 2003 DTC 1007 (TCC)

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Administrative Policy

27 October 2017 Internal T.I. 2017-0694231I7 - Subsection 247(2), surplus, and FAPI

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Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) s. 247(2) transfer pricing adjustment for sales undercharges to a CFA does not decrease the ES of the CFA 163
Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(2) effect on surplus balances of foreign transfer-pricing adjustment might be reversed under Reg. 5907(2) 151
Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(1) - Earnings - Paragraph (a) surplus could be adjusted by transfer-pricing adjustment 134

26 May 2016 IFA Roundtable Q. 6, 2016-0642081C6 - German Organschafts

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Tax Topics - Income Tax Act - Section 90 - Subsection 90(2) profit transfer payments by German sub to its German parent deemed to be dividends under s. 90(2) 319
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(a) - Subparagraph 95(2)(a)(ii) - Clause 95(2)(a)(ii)(B) profit transfer payments made by a German sub to German parent are s. 90(2) dividends not within s. 95(2)(a)(ii)(B) after 2016 153
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) loss compensation payment under Organschaft 123

1 December 2009 Internal T.I. 2009-0324951I7 F - Prix de base rajusté des actions d'une société

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Words and Phrases
contribution of capital

5 December 2003 External T.I. 2002-0165195 - Debt Forgiveness in Foreign Affiliates

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14 July 1999 External T.I. 9917685 - FOREIGN AFFILIATE EARNINGS COMPUTATION

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92 C.R. - Q.28

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10 January 1992 CGA Roundtable, Q. 19, 7-912224

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September 1991 Memorandum (Tax Window, No. 9, p. 7, ¶1444)

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88 C.R. - Q.36 (p. 53:49)

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87 C.R. - Q.68 (p. 47:38)

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IT-456R "Capital Property - Some Adjustments to Cost Base," para. 2

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Articles

Tremblay, "Contributions to Capital - Cost Basis", Canadian Current Tax, October, 1987, p. 1

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Paragraph 53(1)(e)

Subparagraph 53(1)(e)(i)

Administrative Policy

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

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Tax Topics - Income Tax Act - Section 34.2 - Subsection 34.2(2) no partnership-interest ACB addition for inclusion 57

2016 Ruling 2015-0617101R3 - 99(1) and timing of ACB adjustment

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Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) on a s. 98(5) wind-up, the ACB of the transferor partner’s interest is bumped by YTD income 105
Tax Topics - Income Tax Act - Section 99 - Subsection 99(1) year ending with termination was final partnership year 116

10 October 2014 APFF Roundtable Q. 22, 2014-0538161C6 - APFF Conference, Q. 22 - ACB of interests in a partnership

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1 October 2013 External T.I. 2013-0491571E5 - Partial disposition of partnership interest - ACB

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Tax Topics - Income Tax Act - Section 43 - Subsection 43(1) disposition of some partnership units a part disposition 150

9 March 2012 External T.I. 2011-0416611E5 - disposition under paragraph 38(a.3)

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15 December 2010 External T.I. 2009-0349911E5 F - Calcul du PBR d'une participation dans une SEC

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Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.1) withdrawal equalling capital gain realized in year by LP triggered negative ACB gain to limited partner 205

15 July 2008 External T.I. 2008-0275471E5 F - Société de personnes/Ajustement au PBR

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Tax Topics - Income Tax Act - Section 99 - Subsection 99(1) CRA was prepared to rule to avoid double taxation problem prior to the s. 99(1) amendment 173

10 January 2008 External T.I. 2007-0227191E5 F - REVENUS D'UNE SOCIÉTÉ DE PERS. - PART PRIVILÉGIÉE

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Tax Topics - Income Tax Act - 101-110 - Section 103 - Subsection 103(1) common and preferred units can be used as a mechanism for profits to be allocated to each partner’s interest (a single property) 185

29 October 2002 External T.I. 2002-014633 -

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30 November 1997 Ruling 9803733 - TIMING OF ADJUSTMENTS TO PARTNERSHIP ACB.

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Income Tax Technical News, No. 9, 10 February 1997

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Income Tax Technical News, No. 5, 28 July 1995

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27 May 1994 External T.I. 9407285 - PARTNERSHIP - GENERAL

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7 June 1991 T.I. (Tax Window, No. 7, p. 9, ¶1366)

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11 March 1991 T.I. (Tax Window, No. 1, p. 5, ¶1155)

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18 April 1990 T.I. (September 1990 Access Letter, ¶1425)

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Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) 56

88 C.R. - Q.22

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Articles

Margaret D. Paproski, "Partnership Interests and Negative ACB", Business Vehicles, Vol. VI, No. 3, p. 257.

Peter Lee, "Dissolution of Partnership - Calculation of Adjusted Cost Base of Partnership Interest", Business Vehicles, Vol. V, No. 4, 1999, p. 273.

Rinfret, "A Review of the AEC Pipelines Limited Partnership", 1997 Corporate Management Tax Conference Report, c. 7

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Subparagraph 53(1)(e)(iii)

Administrative Policy

9 March 1992 T.I. (Tax Window, No. 17, p. 3, ¶1789)

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3 December 1991 T.I. (Tax Window, No. 15, p. 4, ¶1673)

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16 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 8, ¶1052)

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Tax Topics - Income Tax Act - Section 96 - Subsection 96(1.1) 64

84 C.R. - Q.25

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Subparagraph 53(1)(e)(iv)

See Also

Mitchell v. The Queen, 96 DTC o (TCC)

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Administrative Policy

27 June 2016 External T.I. 2016-0637341E5 F - Partnerships - Negative ACB

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Tax Topics - Income Tax Act - Section 53 - Subsection 53(2) - Paragraph 53(2)(c) - Subparagraph 53(2)(c)(v) loan advances to a limited partner may give rise to immediate s. 53(2)(c)(v) grind 261
Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.1) loans by LP to partner potentially gave rise to negative ACB gain 168
Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.13) retention of partnership profits not a contribution 150

2016 Ruling 2016-0651621R3 - Partnership carried on by sole proprietor

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Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) the assumption by a partner of a debt owing to it by a partnership bumped the partner’s ACB 198
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) - Forgiven Amount no forgiven amount where partner assumed debt owing to it by partnership 48

25 April 2013 Internal T.I. 2013-0478511I7 F - Distribution à un commanditaire

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Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate real estate capital gains flowed through to limited partner retained character 226
Tax Topics - Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(f) allocated capital gains retained their character unless re services performed by partner in course of separate business 397
Tax Topics - Excise Tax Act - Section 272.1 - Subsection 272.1(1) distinction between return on partnership investment and services rendered by partner in the course of a separate business 295

8 October 2010 Roundtable, 2010-0373371C6 F - Souscription des unités d'une SEC

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Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(a) subscription for units of an underwater LP represented an acquisition whose deemed cost was nil 217

3 October 2007 External T.I. 2007-0230671E5 F - Paragraphe 12 du IT-338R2

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2000 Ruling 2000-0028423 - partnership dissolution under 98(3)

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2000 Ruling 2000-0028423 - partnership dissolution under 98(3)

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29 June 2000 External T.I. 1999-0011495 - ACB Partnership Interest

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4 June 1992 T.I. 920847 (December 1992 Access Letter, p. 34, ¶C245-044)

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89 C.R. - Q.35

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Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) 26

89 C.M.TC - Q.8

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IT-338R "Partnership Interest - Effects on Adjusted Cost Base Resulting from the Admission or Retirement of a Partner"

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Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) 10

IT-471R "Merger of Partnerships"

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Subparagraph 53(1)(e)(viii)

Administrative Policy

Income Tax Technical News, No. 12 under "Adjusted Cost Base of Partnership Interest - Subparagraph 53(1)(e)(viii)

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8 September 1997 External T.I. 9642025 - ACB OF PARTNERSHIP INTEREST - RESOURCE CONTEXT

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94 C.P.T.J. - Q. 4

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Paragraph 53(1)(f.1)

Administrative Policy

31 March 2016 External T.I. 2014-0524391E5 F - Debt parking

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Tax Topics - Income Tax Act - Section 80.01 - Subsection 80.01(8) debt parking rule can apply even if no capital loss is recognized 154

12 September 1990 T.I. (Tax Window, Prelim. No. 1, p. 10, ¶1016)

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16 February 1990 T.I. (July 1990 Access Letter, ¶1320)

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2014 Ruling 2013-0514191R3 - Debt restructuring, forgiveness and winding-up

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Principal Amount non-application of s. 39(2) to exchange of U.S.-dollar notes 142
Tax Topics - Income Tax Act - Section 39 - Subsection 39(2) s. 51.1 exchange of U.S.-dollar notes 142
Tax Topics - Income Tax Act - Section 51.1 s. 51.1 exchange of U.S.-dollar notes 142
Tax Topics - Income Tax Act - Section 80.01 - Subsection 80.01(4) s. 51.1 exchange of U.S.-dollar notes and ATR-66 debt slide 430

Paragraph 53(1)(h)

Administrative Policy

3 May 2010 Internal T.I. 2010-0359631I7 F - Dépenses liées à une résidence non habitée

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Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base property taxes not added to ACB of inherited property before its sale 133

88 C.R. - Q.68

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Paragraph 53(1)(j)

Administrative Policy

9 February 2010 Internal T.I. 2009-0333571I7 F - Paragraphe 7(1.5) - contrepartie reçue

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Tax Topics - Income Tax Act - Section 7 - Subsection 7(1.5) s. 7(1.5) rollover where employees exchanged specific s. 7(1.1) shares for shares of grandparent, even though they also received cash and PUC distribution 454
Tax Topics - Income Tax Act - Section 116 - Subsection 116(1) s. 116 certificate required even for shares disposed of under s. 7(1.5) rollover 283
Tax Topics - Income Tax Act - Section 7 - Subsection 7(1.4) non-resident ex-employees will be required to recognize s. 7 benefit deferred by s. 7(1.5) when they dispose of the shares acquired in exchange 148

Paragraph 53(1)(n)

Administrative Policy

7 October 2011 Roundtable, 2011-0411971C6 F - Appraisal Fees Deductibility

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense deductible appraisal fees to revalue fixed assets in accordance with IFRS 103

Subsection 53(2) - Amounts to be deducted

Paragraph 53(2)(b)

Administrative Policy

2003 Ruling 2002-0174703 - Foreign Affiliate Reorganization

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Paragraph 53(2)(c)

Administrative Policy

27 March 2013 External T.I. 2012-0449661E5 F - Subparagraph 53(2)(c) ITA

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10 January 2005 External T.I. 2004-0075931E5 - adjusted cost base - partnership interest

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(12) no partnership ACB reduction for partner s. 20(12) deduction 190

Subparagraph 53(2)(c)(i)

Administrative Policy

29 August 2007 Internal T.I. 2007-0219931I7 F - Perte sur taux de change - société de personnes

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Tax Topics - Income Tax Act - Section 39 - Subsection 39(2) s. 39(2) gain to partnership when USD advance owing by it is converted to units 90

Income Tax Technical News, No. 5, 28 July 1995

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Clause 53(2)(c)(i)(B)

Administrative Policy

13 January 2009 External T.I. 2008-0296981E5 F - Ajustement au PBR d'une participation

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Subparagraph 53(2)(c)(v)

Cases

Tesainer v. Canada, 2009 DTC 5749, 2009 FCA 33

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Stursberg v. The Queen, 93 DTC 5271, [1993] 2 CTC 46, 93 DTC 5275, [1993] 2 CTC 76 (FCA)

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Words and Phrases
distribution
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition partial disposition of partnership interest to a related corporation, even though proceeds run through the partnership 114

See Also

Tesainer v. The Queen, 2008 DTC 2807, 2008 TCC 101

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Administrative Policy

27 June 2016 External T.I. 2016-0637341E5 F - Partnerships - Negative ACB

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Words and Phrases
in lieu of on account of
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.1) loans by LP to partner potentially gave rise to negative ACB gain 168
Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.13) retention of partnership profits not a contribution 150
Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(iv) assumption of loan can be contribution, but not retained profits 177

20 August 2008 External T.I. 2008-0288561E5 F - Convention de partage d'une société de personnes

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Tax Topics - Income Tax Act - Section 96 - Subsection 96(1.1) no income could be allocated under s. 96(1.1) where aggregate income was nil 119
Tax Topics - Income Tax Act - 101-110 - Section 103 - Subsection 103(1) CRA generally does not challenge sharing agreements based on each partner’s contribution 56

11 April 1995 External T.I. 9508655 - PARTNERSHIP AT-RISK RULES RE LOAN

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19 April 1990 T.I. (September 1990 Access Letter, ¶1414)

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Paragraph 53(2)(h)

Articles

Goodman, "The Tax Treatment of Commercial Trusts", 1989 Canadian Tax Journal, July-August issue, p. 1053

Subparagraph 53(2)(h)(i.1)

Administrative Policy

2010 Ruling 2009-0330901R3 - Reorganization of XXXXXXXXXX

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Tax Topics - Income Tax Act - 101-110 - Section 107 - Subsection 107(2.1) recognition of capital loss on distribution of capital gain through redemption of most of trust units by corporate unitholder 100
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) - Forgiven Amount no forgiven amount on transfer by unit trust to its parent of debt owing by parent 36

23 April 2009 External T.I. 2008-0301241E5 F - Fiducie d'invest. à participation unitaire-75(2)

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Tax Topics - Income Tax Act - Section 75 - Subsection 75(2) s. 75(2) generally not applied to commercial unit trust where single class of units subscribed for on FMV terms 277
Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) doubtful that s. 248(28)(a) can be applied to preclude ACB grind 181

4 November 2008 External T.I. 2008-0264181E5 - Income recognition and ACB - trust units

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Words and Phrases
included

2007 Ruling 2007-0245281R3 - windup of income trust on sale of assets:3rd party

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Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.3) capital loss on redemption of trust units following distribution of most of its assets including as capital gains distribution 110
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(21) trustees making filings on behalf of terminated fund 48
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) assumed debt traceable to capital distribution 97
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(6) realization and distribution of target MFT gain 101
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) 90
Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) 90

2007 Ruling 2007-0237011R3 - XXXXXXXXXX - foreign buy-out of Canadian MFT

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11 January 1996 External T.I. 9521525 - EFFECT OF NET CAPITAL LOSS ON ACB OF TRUST UNITS

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Clause 53(2)(h)(i.1)(B)

Subclause 53(2)(h)(i.1)(B)(I)

Administrative Policy

7 November 2007 Internal T.I. 2007-0253861I7 F - Partie non-imposable du gain en capital

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Tax Topics - Income Tax Act - Section 132.1 - Subsection 132.1(2) no ACB increase under s. 132.1(2) if no previous reduction under s. 53(2)(h)(i.1) 273

Paragraph 53(2)(k)

Administrative Policy

11 October 1991 T.I. (Tax Window, No. 11, p. 18, ¶1517)

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Subsection 53(2.1) - Election

Administrative Policy

1993 A.P.F.F. Round Table, Q. 21

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IT-273R2, "Government Assistance - General Comments," para. 12

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