Subsection 5903(3)
See Also
Trans World Oil & Gas Ltd. v. The Queen, 95 DTC 260, [1995] 1 CTC 2087 (TCC), briefly aff'd 98 DTC 6060 (FCA)
A U.S. resident corporation ("Trans World U.S.") that incurred business losses while it was owned by a Canadian-resident individual and then was...
Administrative Policy
21 October 1992 Memorandum (Tax Window, No. 27, p. 13, ¶2345; October 1993 Access Letter, p. 476)
Where the amalgamation of two unrelated taxable Canadian corporations precedes the merger of their respective wholly-owned U.S. subsidiaries under...
Subsection 5903(5)
Paragraph 5903(5)(b)
Administrative Policy
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 5908 - Subsection 5908(10) | partnership interests no longer were excluded property on dissolution given prior disposition of s. 95(2)(a)(ii) loans/potential qualification of partnership interest under para. (c) ignored | 297 |
| 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 |