27 March 2018 Internal T.I. 2015-0592551I7 - Excluded property status of partnership interest
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|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||383|
|Tax Topics - Income Tax Act - Section 96||Icelandic Sameignarfelag was partnership||183|
|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||248|
|Tax Topics - Income Tax Act - Section 98 - Subsection 98(2)||partnership interest disposition occurred no sooner than final distribution date||79|