Subsection 93.2(2)
Administrative Policy
26 April 2017 IFA Roundtable Q. 3, 2017-0691131C6 - U.S. LLPs and LLLPs
CRA briefly noted that s. 93.2 would apply to Florida and Delaware LLPs and LLLPs that are treated by CRA as corporations.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 96 | further extension of grandfathering relief for Florida and Delaware LLPs and LLLPs | 182 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation | general grandfathering of pre-April 26, 2017 LLPs and LLLPs | 115 |
| Tax Topics - Treaties - Income Tax Conventions - Article 4 | Florida and Delaware LLPs and LLLPs treated like LLCs | 28 |
2016 Ruling 2015-0571441R3 - Dutch Cooperative - 93.2 & 95(2)(c)
Before ruling that the contribution of shares of a Netherlands private limited liability company to a newly-formed Dutch cooperative (DC), in...
| 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 | 502 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation | Dutch cooperative whose articles limited member liability was a corp | 263 |
| 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 | 130 |
| 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 | 57 |
16 June 2014 STEP Roundtable, 2014-0522971C6 - STEP CRA Roundtable June 2014 - Question 3
The "formula" for the equity interests in a U.S. LLC provides for the manager to receive incentive compensation in the form of a 2% income...
Articles
Paul Barnicke, Melanie Huynh, "Deemed Shares in a US LLC", Canadian Tax Highlights, Vol. 22, No. 8, August 2014, p. 8.
Application of 2014-0522971C6 to an LLC that already has "shares" (p.8)
The TI involves a US LLC that is formed "in a way similar to "a...
Subsection 93.2(3)
Administrative Policy
26 May 2016 IFA Roundtable Q. 10, 2016-0642101C6 - 93.2 & 95(2)(c)
Canco owns all the shares of FA1, which owns all the shares of FA2 and all the member interests of FA3, which is a “non-resident corporation...
| 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 | 154 |
| 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 | 129 |