Section 272.1

Subsection 272.1(1)

Administrative Policy

30 December 2013 Ruling 136499

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25 April 2013 Internal T.I. 2013-0478511I7 F - Distribution à un commanditaire

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate real estate capital gains flowed through to limited partner retained character 216
Tax Topics - Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(f) allocated capital gains retained their character unless re services performed by partner in course of separate business 381
Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(iv) services rendered by limited partner to LP gave rise to ACB increase if no s. 9 income inclusion for fee income 127

Canadian Bar Association CRAG ST Round Table 9 March 2006, Q. 13

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30 June 2005 Headquarters Letter RITS No. 57840

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P-244 - "Partnerships - Application of Subsection 272.1(1) of the Excise Tax Act", 9 August 2004

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26 May 2004 Interpretation RITS No. 49475

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26 May 2004 Interpretation RITS No. 36728

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P-216 - "Registration of a Partner", 8 April 1998

Subsection 272.1(2)

See Also

FP Newspapers Inc. v. The Queen, 2013 TCC 44 (Informal Procedure)

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B.J. Northern Enterprises Ltd. v. The Queen, [1995] GSTC 12 (TCC)

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Administrative Policy

May 2016 Alberta CPA Roundtable, GST Q.2

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26 June 2013 Opinion Case No. 144410

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CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 29 ("Real Property Investment")

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1 August 2003 Ruling Case No. 39572

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27 September 2002 Headquarter Letter Case No. 39625

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23 September, 1998 Headquarters Letter RITS No. HQR000265

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Subsection 272.1(3)

Commentary

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Administrative Policy

GST/HST Notice 308 GST/HST and Investment Limited Partnerships July 2018

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Subsection 272.1(5)

See Also

Raposo v. The Queen, 2018 CCI 81

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Illegality partnership for illegal activity was void under Art. 1417 of the Civil Code 148
Tax Topics - Income Tax Act - Section 96 illegality of partnership business voided the partnership 131

Subsection 272.1(6)

Administrative Policy

GST/HST Memoranda Series 2.7 Cancellation of Registration May 2005

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 271 79

Subsection 272.1(7)

Administrative Policy

1 May 2003 Draft Policy P-XX5

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Articles

Brent Murray, "Partner Changes: Have the 'Simplified' Partnership Rules Gotten More Complicated?", GST & Commodity Tax, Vol. XVII, No. 5, June 2003, p. 37.

Subsection 272.1(8)

Commentary

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Administrative Policy

GST/HST Notice 308 GST/HST and Investment Limited Partnerships July 2018

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Articles

Alan Kenigsberg, "Changes to Tax Treatment of ILPs under the ETA", Sales Tax, Customs & Trade, Volume XV, No 2, Federated Press, 2018, p.9

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Allan Gelkopf, Robert Kreklewich, Zvi Halpern-Shavim, "Finance Canada Seeks Comments on New Tax Proposals Regarding Investment Limited Partnership Rules", Canadian Current Tax, Vol. 28, No.1, October 2017 p. 4

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