An insurance corporation (that reinsures policies issued by another insurer) holds partnership interests in several partnerships that have no...
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|Tax Topics - Income Tax Regulations - Regulation 400 - Subsection 400(1)||a partner is attributed each PE of a partnership for Reg. 400(1) purposes||230|
The taxpayer, a Canadian property insurer insures risk inside and outside Canada, but has no permanent establishment (“PE”) outside Canada....