Administrative Policy
27 July 2021 GST/HST Interpretation 197267a - Allocation to a general partner
CRA, in commenting regarding the application of GST/HST to allocations of income, dividends and taxable capital gains allocations of income,...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 272.1 - Subsection 272.1(1) | draws to GP disproportionate to partnership capital is indicative of the receipt by it of such draws as consideration for services | 288 |
| Tax Topics - Excise Tax Act - Section 272.1 - Subsection 272.1(3) - Paragraph 272.1(3)(b) | a manager cannot earn its fee directly from the ILP, and the deemed FMV supply by the GP is based on industry norms | 324 |
28 February 2019 CBA Roundtable, Q.25
Each scenario provides a variant of Example 1 in Notice 308 respecting a limited partnership (LP) that is established to offer investment...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 272.1 - Subsection 272.1(3) | fees of general partner are taxable even if not charged to ILP | 120 |
GST/HST Notice 308 GST/HST and Investment Limited Partnerships July 2018
Example 1 of limited partnership that uses the subscription proceeds raised under a prospectus to invest in other LPs investing in commercial real...
International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation:The FATF Recommendations June 2017
FATF concept of "financial institution" (referenced by CRA in FATCA context) (pp. 116-7)
Financial Institutions means any natural or legal person...
Guidance on the Canada-U.S. Enhanced Tax Information Exchange Agreement 20 July 2020
Scope of collective investment vehicle concept
3.20 An entity that primarily conducts as a business investing, administering, or managing...
Articles
PWC, "Tax Insights: Investment limited partnerships ─ GST/HST & QST filing obligations", Issue 2020-27, May 04, 2020
Meaning of “principal activity”
A person’s “principal activity,” as discussed … in College of Applied Arts … depends on how...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 225.4 - Subsection 225.4(6) | 198 |
Alan Kenigsberg, "Changes to Tax Treatment of ILPs under the ETA", Sales Tax, Customs & Trade, Volume XV, No 2, Federated Press, 2018, p.9
Purpose of ILP rules (p. 9)
We understand that the new measures were aimed at preventing certain investment funds from structuring their affairs...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 217.1 - Subsection 217.1(1) | 158 | |
| Tax Topics - Excise Tax Act - Section 272.1 - Subsection 272.1(8) | 52 |
Commentary
3 tests in ILP definition
An “investment limited partnership” is defined in the draft legislation released on September 8. 2017 (and...