Section 93.2

Subsection 93.2(2)

Administrative Policy

26 April 2017 IFA Roundtable Q. 3, 2017-0691131C6 - U.S. LLPs and LLLPs

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 96 further extension of grandfathering relief for Florida and Delaware LLPs and LLLPs 166
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation general grandfathering of pre-April 26, 2017 LLPs and LLLPs 105
Tax Topics - Treaties - Income Tax Conventions - Article 4 Florida and Delaware LLPs and LLLPs treated like LLCs 26

2016 Ruling 2015-0571441R3 - Dutch Cooperative - 93.2 & 95(2)(c)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(c) rollover is available on joint drop-down of shares of a Dutch private limited liability company into a Dutch cooperative in consideration for respective credits to the membership accounts 455
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation Dutch cooperative whose articles limited member liability was a corp 251
Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Controlled Foreign Affiliate non-resident subsidiaries CFAs of bottom-tier Cdn partnership and FAs of Canadian corporate partners 126
Tax Topics - Income Tax Act - Section 85.1 - Subsection 85.1(3) joint contribution of shares of FA to Netherlands co-op in consideration for credits to their respective membership accounts deemed to be for share consideration 55

16 June 2014 STEP Roundtable, 2014-0522971C6 - STEP CRA Roundtable – June 2014 - Question 3

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Articles

Paul Barnicke, Melanie Huynh, "Deemed Shares in a US LLC", Canadian Tax Highlights, Vol. 22, No. 8, August 2014, p. 8.

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Subsection 93.2(3)

Administrative Policy

26 May 2016 IFA Roundtable Q. 10, 2016-0642101C6 - 93.2 & 95(2)(c)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(c) dropdown of shares made to an LLC as a contribution of capital deemed by s. 93.2(3) to be for "share” consideration 150
Tax Topics - Income Tax Act - Section 85.1 - Subsection 85.1(3) drop-down of FA shares to non-share FA deemed to be for share consideration 124