Section 93.1

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

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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

6 September 2002 External T.I. 2001-011167 -

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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 220
Tax Topics - Income Tax Act - Section 91 - Subsection 91(5) appplication of s. 91(5) to LP shareholder of FA 86