Subsection 231(6)
See Also
Paletta v. The Queen, 2019 TCC 205, aff'd 2021 FCA 182
A taxpayer used U.S.$82M that had largely been indirectly financed by Twentieth Century Fox to fund, as partner, prints and advertising expenses...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Sham | film marketing partnership loss denied on the basis that an alleged option was a sham | 415 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | expenses non-deductible because partnership expected to be repurchased before any income generated | 127 |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | rental revenues were incidental to secondary intention save for land with 25-year hold | 309 |
| Tax Topics - General Concepts - Evidence | TCC not bound by admission contrary to facts where benefiting party has adduced evidence on point | 50 |
Maya Inc. c. La Reine, 2004 DTC 2001, 2003 TCC 502
In disclosure documents the taxpayer, which was a non-resident company that was promoting a proposed plantation in Costa Rica, specified that 99%...
Administrative Policy
17 May 1990 T.I. (October 1990 Access Letter, ¶1485)
The representations referred to include verbal suggestions.
If a limited partner is not required to repay the advances received by him (on the...
8 May 1990 T.I. (October 1990 Access Letter, ¶1486)
Where the promoter of a hotel limited partnership would attempt to place some mortgage on the hotel after the third year of operations, with the...
27 March 1990 T.I. (August 1990 Access Letter, ¶1390)
Where under a revenue guarantee the limited partner will receive a specified amount of annual gross revenues in excess of the annual gross...
26 February 1990 T.I. (July 1990 Access Letter, ¶1343)
Where the liability for repaying all cash guarantees rests with the investor and the guarantees are structured as loan arrangements, it is still a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 237.1 - Subsection 237.1(1) - Tax Shelter | 109 |
18 September 89 T.I. (February 1990 Access Letter, ¶1126)
S.231(6)(a)(ii) would include the amount of non-recourse or limited recourse financing owing to any other person by the purchaser or to a person...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 237.1 - Subsection 237.1(1) - Tax Shelter | 17 |
Subsection 231(6.1)
Articles
Donald H. Watkins, "The Tax-Shelter Rules: An Update", 1998 Conference Report, c.5.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 143.2 - Subsection 143.2(6) | 0 | |
| Tax Topics - Income Tax Act - Section 237.1 - Subsection 237.1(2) | 0 |
Subsection 231(7)
Administrative Policy
12 February 1990 T.I. (July 1990 Access Letter, ¶1342)
Shares of a Canadian corporation which are held by a taxpayer in a stock savings plan prescribed in Regulation 6705 are "prescribed property" for...