Investment Limited Partnership

Commentary

3 tests in ILP definition

An “investment limited partnership” is defined in the draft legislation released on September 8. 2017 (and...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

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,...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
principal activity
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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.