Section 92

Subsection 92(1) - Adjusted cost base of share of foreign affiliate

Paragraph 92(1)(a)

Administrative Policy

27 June 2008 External T.I. 2007-0247551E5 - FAPI and Part XIII Tax

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 96 DRUPA partnership 34
Tax Topics - Income Tax Regulations - Regulation 5900 - Subsection 5900(3) partnership between 2 CFAs was a Cdn-resident person for s. 91(5) purposes 65
Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Foreign Accrual Property Income - A - Paragraph (b) FA dividends received by NR partnership between 2 CRAs (FP) not excluded from FAPI, but deduction under s. 91(5) to FP 273

4 September 1990 External T.I. 5-9693

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Articles

Allan Lanthier, "FAPI or Taxable Surplus Dividend", Canadian Tax Highlights, Vol. 23, No. 2, February 2015, p. 4.

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 92(5) - Deemed gain from the disposition of a share

Administrative Policy

7 May 2014 Internal T.I. 2012-0433731I7 - Application of subsections 92(5) and (6)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

22 May 2014 IFA Roundtable, 2014-0526751C6 - Adjusted cost base of foreign affiliate shares

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 90 - Subsection 90(6) no relief from interest and penalties 109
Tax Topics - Income Tax Act - Section 90 - Subsection 90(6) s. 90(6) relationship tested at time of loan 353

Articles

Geoffrey S. Turner, "ACB Adjustments for Foreign Affiliate Shares Held Through Partnerships", International Tax (Wolters Kluwer CCH), No. 79, December 2014, p. 1.

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paul Barnicke, Melanie Huynh, "FA Shares Held in Partnership", Canadian Tax Highlights, Vol 22, No 6, June 2014, p. 8

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.