Words and Phrases - "on account of"
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...
Locations of other summaries | Wordcount | |
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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...
Locations of other summaries | Wordcount | |
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Tax Topics - General Concepts - Onus | no onus to rebut a factual assmption re something not within the taxpayer's purview | 170 |