Subsection 5908(4)
Administrative Policy
21 February 2013 External T.I. 2012-0435881E5 - Wind-up and Reg. 5908
Parent, and its immediate wholly-owned subsidiary (Subsidiary), have 1% and 99% respective partnership interests in Partnership, which owns all...
Subsection 5908(8)
Subsection 5908(9)
Articles
Michael Colborne, Michael McLaren, "Section 93 Elections — Proposed Amendments", Canadian Tax Journal, Vol. 58, 2010, p.357.
Preserves surplus adjustments for multi-tier partnerships (p. 378).
[P]roposed regulation 5908 ensures that a corporate partner of a partnership...
Subsection 5908(10)
Administrative Policy
27 March 2018 Internal T.I. 2015-0592551I7 - Excluded property status of partnership interest
An Iceland “Sameignarfelag” (viewed by CRA as a partnership), which had been serving as a Finco to foreign affiliates in a Canadian...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Excluded Property | partnership interests no longer were excluded property on dissolution given prior disposition of s. 95(2)(a)(ii) loans | 551 |
| Tax Topics - Income Tax Regulations - Regulation 5903 - Subsection 5903(5) - Paragraph 5903(5)(b) | foreign affiliate parent cannot carry back FAPLs generated by wound-up foreign affiliate | 389 |
| Tax Topics - Income Tax Act - Section 96 | Icelandic Sameignarfelag was partnership | 198 |
| Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.14) | once partnership interests were no longer excluded property, the components of their ACB calculation was to be translated at the rates when those components first arose | 254 |
| Tax Topics - Income Tax Act - Section 98 - Subsection 98(2) | partnership interest disposition occurred no sooner than final distribution date | 79 |
Articles
Marc Ton-That, Melanie Huynh, "Inconsistent Treatment of Partnerships in the Foreign Affiliate Rules,", 2009 Conference Report (Toronto: Canadian Tax Foundation, 2010), 24:1-61.
No application to lower-tier LP interests (pp. 24:16-17)
Regulation 5907(12) applies only to determine the ACB in a partnership interest held by a...