Words and Phrases - "on account of"

a
89
b
44
c
82
d
56
e
41
f
31
g
20
h
15
i
75
j
2
k
2
l
32
m
57
n
27
o
38
p
81
q
3
r
78
s
93
t
47
u
16
v
10
w
23
y
2

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

Summary Under
Tax Topics - Income Tax Act - Section 53 - Subsection 53(2) - Paragraph 53(2)(c) - Subparagraph 53(2)(c)(v)
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 164
Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.13) retention of partnership profits not a contribution 146
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

Summary Under
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1)
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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Words and Phrases
on account of in satisfaction of in lieu of rent au titre
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