Old 34.2
Administrative Policy
4 May 2004 Internal T.I. 2004-0062671I7 F - Associé qui se joint à une société de personnes
A taxpayer departed a partnership in respect of which he had been annually deducting a reserve from income on December 31, 1995 to join another...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 249.1 - Subsection 249.1(4) | taxpayer bound by previous off-calendar year election of partnership which he joined | 347 |
19 February 1997 External T.I. 9624745 - FISCAL PERIOD - JUDGES
A newly-appointed judge is provided with a numerical example "which reflects that the allocation of income between the year of appointment and the...
20 February 1997 Internal T.I. 9637077 - FISCAL PERIOD - SIMILAR SERVICES
"It is unlikely that the services of a financial planner would be considered to be similar to those of an accountant. In any event, in your...
Subsection 34.2(1) - Definitions
Adjusted Stub Period Accrual Income
Administrative Policy
12 April 2012 External T.I. 2012-0436121E5 - ASPA, QTI and significant interest
A corporation with a July 31 taxation year holds an interest in a single-tier partnership with August 31 fiscal period ends. However, the...
8 February 2012 External T.I. 2011-0425411E5 - Change in fiscal period & transitional reserve
a corporation with a June 30 year end and which is a member of a calendar year partnership switches to a calendar year. Discussion including...
Articles
Janette Pantry, Robyn Campbell, "Partnerships and ASPA on Acquisition of Control", Canadian Tax Highlights, Vol. 24, No. 10, October 2016, p. 3
Assumptions respecting application of adjusted stub period accrual (ASPA) rules (p.3)
Assume that Partnership AB has a limited partner (ACo) whose...
Shane Onufrechuk, Warren Pashkowick, "Tax Considerations of Major Construction Projects", 2014 Conference Report, Canadian Tax Foundation, 10:1-35.
Deferral with choice of partnership year-end with partnership in start-up (p. 10:5)
Many major construction projects are not taxable for a number...
Paragraph (a)
Element B
Administrative Policy
12 June 2020 External T.I. 2018-0788161E5 F - Adjusted stub period accrual amount
Opco, with a November 30 year end, holds, as a limited partner, a significant interest in a calendar year partnership ("LP"), which had previously...
Subsection 34.2(2) - Income inclusion — adjusted stub period accrual
Administrative Policy
10 May 2017 External T.I. 2017-0687051E5 F - Addition to ACB of a partnership interest
CRA considered that an amount included in a corporation’s income under s. 34.2(2) will not be added to the adjusted cost base of its partnership...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(i) | no s. 53(1)(e) addition for s. 34.2(2) stub period income inclusion | 127 |
4 November 2014 External T.I. 2014-0539191E5 - ASPA under 34.2(2)
Corp A, which has a significant interest in a partnership which, like Corp A, has a calendar year end, amalgamates on august 1, 2014 so that it...
Subsection 34.2(11) - Transitional reserve
Administrative Policy
2015 Ruling 2015-0601441R3 - XXXXXXXXXX Partnership - winding up
Current structure
Sub1 and Sub2 (both taxable Canadian corporations and wholly-owned subsidiaries of Parent who, like them, has a calendar year...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) | 98(5) wind-up through s. 85 transfer of partnership interest of one partner to the other and preceded by debt assumptions | 292 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(ii) | interest deductible following assumption of interest-bearing internal debt on s. 98(5) wind-up | 297 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) | continued availability of s. 20(1)(m) reserve following s. 98(5) wind-up | 296 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(n) | flow-through of s. 20(1)(n) reserve on s. 98(5) wind-up | 289 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(24) | s. 20(24) election on s. 98(5) wind-up | 307 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(9) | s. 18(9) deduction claimable by transferee former partner following s. 98(5) wind-up | 241 |
| Tax Topics - Income Tax Act - Section 147.2 - Subsection 147.2(8) | s. 147.2 continuity following s. 98(5) wind-up | 368 |
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(i) | no income inclusion on assumption on s. 98(5) wind-up of DSUs and RSUs | 356 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Salary Deferral Arrangement - Paragraph (k) | no income on RSU/DSU assumption | 22 |
9 April 2014 External T.I. 2013-0503421E5 F - Transitional reserve
Can a corporation with qualifying transitional income respecting a partnership in which it has a significant interest claim a transitional reserve...
14 February 2014 External T.I. 2012-0454481E5 F - Safe Income
The only source of income of ABC, a CCPC, is its interest in a partnership with a fiscal period end of XX. ABC has an income inclusion under s....
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) | not claiming s. 34.2(11) transitional reserve to increase SIOH | 379 |
| Tax Topics - Income Tax Act - Section 55 - Subsection 55(5) - Paragraph 55(5)(c) | no departures permitted from s. 34.2 adjustments | 194 |
Subsection 34.2(13) - No reserve
Paragraph 34.2(13)(a)
Administrative Policy
4 December 2013 External T.I. 2013-0499681E5 - Transitional reserve - tiered partnership
Can a corporate partner of a top-tier partnership in a multi-tier partnership structure continue to claim a transitional reserve under s. 34.2(11)...
Subsection 34.2(14) - Deemed partner
Administrative Policy
2014 Ruling 2013-0516071R3 - Reorganization
The units of an LP (LP1) which already has earned profits for the year and which holds most of the units of LP2 will be transferred to a Lossco...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a) | transfer of already-earned profits to Lossco by transfer of LP units with income allocation at LP year end | 326 |
| Tax Topics - Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(f) | transfer of profitable LP to Lossco followed by allocation of previously-earned profits of LP to Lossco | 95 |