21 February 2013 External T.I. 2012-0435881E5 - Wind-up and Reg. 5908
Parent, and its immediate wholly-owned subsidiary (Subsidiary), have 1% and 99% respective partnership interests in Partnership, which owns all...
Michael Colborne, Michael McLaren, "Section 93 Elections — Proposed Amendments", Canadian Tax Journal, Vol. 58, 2010, p.357.
Preserves surplus adjustments for multi-tier partnerships (p. 378).
[P]roposed regulation 5908 ensures that a corporate partner of a partnership...
27 March 2018 Internal T.I. 2015-0592551I7 - Excluded property status of partnership interest
An Iceland “Sameignarfelag” (viewed by CRA as a partnership), which had been serving as a Finco to foreign affiliates in a Canadian...
|Locations of other summaries||Wordcount|
|Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Excluded Property||partnership interests no longer were excluded property on dissolution given prior disposition of s. 95(2)(a)(ii) loans||551|
|Tax Topics - Income Tax Regulations - Regulation 5903 - Subsection 5903(5) - Paragraph 5903(5)(b)||foreign affiliate parent cannot carry back FAPLs generated by wound-up foreign affiliate||389|
|Tax Topics - Income Tax Act - Section 96||Icelandic Sameignarfelag was partnership||198|
|Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.14)||once partnership interests were no longer excluded property, the components of their ACB calculation was to be translated at the rates when those components first arose||254|
|Tax Topics - Income Tax Act - Section 98 - Subsection 98(2)||partnership interest disposition occurred no sooner than final distribution date||79|
Marc Ton-That, Melanie Huynh, "Inconsistent Treatment of Partnerships in the Foreign Affiliate Rules,", 2009 Conference Report (Toronto: Canadian Tax Foundation, 2010), 24:1-61.
No application to lower-tier LP interests (pp. 24:16-17)
Regulation 5907(12) applies only to determine the ACB in a partnership interest held by a...