Words and Phrases - "reasonably attributable"

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b
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d
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24 October 2018 Internal T.I. 2018-0741041I7 - Allocation of net premiums under s. 403(4)

Summary Under
Tax Topics - Income Tax Regulations - Regulation 403 - Subsection 403(4)
methodology for allocating out of Canada net premiums

The taxpayer, a Canadian property insurer insures risk inside and outside Canada, but has no permanent establishment (“PE”) outside Canada....

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Words and Phrases
reasonably attributable

Devon Canada Corporation v. The Queen, 2013 TCC 415

Summary Under
Tax Topics - Income Tax Act - Section 66.7 - Subsection 66.7(10) - Paragraph 66.7(10)(j)
drop-down to 2nd tier partnership following deemed successoring

Following an acquisition of control of a predecessor of the taxpayer (Home Oil), a partnership of which Home Oil was a direct member (the Anderson...

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Words and Phrases
reasonably attributable
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 102 - Subsection 102(2) source preservation in 2-tier partnership 84