Subsection 99(1) - Fiscal period of terminated partnership
See Also
MacDonellv. MNR, 54 DTC 14 (ITAB)
The withdrawal by the taxpayer from a firm of chartered accountants did not lead to any change in the partnership's fiscal period in light inter...
Administrative Policy
2016 Ruling 2015-0617101R3 - 99(1) and timing of ACB adjustment
The sole limited partner (LPco) transfers it interest in an LP under s. 85(1) to the general partner (GPco), thereby triggering the simultaneious...
Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(i) | ACB of limited partner’s and GP’s interest increased by YTD income on s. 98(6) wind-up arising on GP’s s. 85 purchase of limited partner’s interest | 304 |
Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) | on a s. 98(5) wind-up, the ACB of the transferor partner’s interest is bumped by YTD income | 105 |
6 January 2014 External T.I. 2013-0477711E5 - Limited partnership losses and dissolution
A sale of assets by a limited partnership before a cessation of its operations resulted in a terminal loss. Before addressing an at-risk amount...
Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 96 - Subsection 96(2.1) | partnership termination | 124 |
15 July 2008 External T.I. 2008-0275471E5 F - Société de personnes/Ajustement au PBR
Pending the amendment to s. 99(1), will CRA apply the Act such that the income or loss of a partnership for its last taxation year before its...
Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(i) | CRA intent to avoid double taxation from untimely basis adjustment for earned income | 45 |
Subsection 99(2) - Fiscal period of terminated partnership for individual member
Cases
Darke v. MNR, 76 DTC 6468, [1976] CTC 734 (FCTD)
Sweet, D.J. stated, obiter, that "the end of the term of a partnership and the completion of the winding up of its affairs may not necessarily be...