Subsection 197(1) - Definitions
Non-Portfolio Earnings
Administrative Policy
10 January 2011 External T.I. 2010-0377081E5 - Meaning of non-portfolio earnings
Where a SIFT holds all the shares of a foreign affiliate, and the SIFT's only transactions with the foreign affiliate are loans to the foreign...
SIFT Partnership
Administrative Policy
2024 Ruling 2023-0997921R3 - Code 3 - XXXXXXXXXX SIFT Ruling Request
A REIT (i.e., a listed unit trust qualifying as a REIT for ITA purposes) indirectly purchased a property from a Canadian-resident tax-exempt...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 122.1 - Subsection 122.1(1) - Investment - Paragraph (a) - Subparagraph (a)ii) | exchangeable preferred units of sub LP of REIT did not replicate return on REIT units | 728 |
| Tax Topics - Income Tax Act - Section 104 - Subsection 104(7.1) | same proportionate taxable income allocation on sub LP exchangeable units avoided circumvention of s. 104(7.1) | 121 |
Subsection 197(2) - Tax on partnership income
Articles
Colin Campbell, "Libility for the Tax on SIFT Partnerships: A Rejoinder", 2011 Canadian Tax Journal, Vol 59, p. 709
Suggests that the phrase "liable to" can create a liability to tax; and that, in any event, the creation of liability to tax, viewed as merely an...
Brian Bloom, Brandon Wiener, "Has Parliament Failed To Charge the 'Tax on SIFT Partnerships?", 2011 Canadian Tax Journal, Vol 59, p. 1
The "liable to" wording of s. 197(2) fails to create an immediate obligation to pay the SIFT tax because it does not specify that such tax is to...