Subsection 93.1(1) - Shares held by partnership
Articles
Karthika Ariyakumaran, Michael Spinelli, "Holding a Foreign Affiliate Through a Partnership", Canadian Tax Focus (Canadian Tax Foundation), Vol. 8, No. 1, February 2018, p.14
Nathan Boidman, "Canadian Foreign Affiliate Tax Proposals - Brief Overview", Tax Management International Journal, Vol. 29, No. 2, 11 February 2000, p. 100.
Subsection 93.1(2) - Where dividends received by a partnership
Administrative Policy
Paragraph 93.1(2)(a)
Articles
Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114
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Paragraph 93.1(2)(d)
Subparagraph 93.1(2)(d)(i)
Administrative Policy
16 May 2018 IFA Roundtable Q. 3, 2018-0749171C6 - Interaction s.91(5) s.93.1(2)(d)(i)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 5900 - Subsection 5900(3) | corporate-owned LP treated transparently to avoid a surplus anomaly re s. 91(5) dividend | 226 |
| Tax Topics - Income Tax Act - Section 91 - Subsection 91(5) | appplication of s. 91(5) to LP shareholder of FA | 88 |
Articles
Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114
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.