Words and Phrases - "on account of"

85
44
75
50
38
31
18
14
72
2
2
32
54
25
38
79
3
76
88
46
15
9
22
2
1

27 June 2016 External T.I. 2016-0637341E5 F - Partnerships - Negative ACB

loan advances to a limited partner may give rise to immediate s. 53(2)(c)(v) grind

Rather than making current distributions of its cash flow to a limited partner, those sums are lent by the LP to the limited partner – then at...

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Words and Phrases
in lieu of on account of
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.1) loans by LP to partner potentially gave rise to negative ACB gain 168
Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.13) retention of partnership profits not a contribution 150
Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(iv) assumption of loan can be contribution, but not retained profits 177

Transocean Offshore Ltd. v. Canada, 2005 DTC 5201, 2005 FCA 104

damages to lessor for advance lease repudiation were in lieu of rent

Lump-sum damages received by the non-resident taxpayer from Canadian residents for the repudiation, prior to the slated operational commencement...

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Onus no onus to rebut a factual assmption re something not within the taxpayer's purview 170