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The Federal Court of Appeal Applies GAAR in a Partnership Loss Transfer Strategy: Canada v. 594710 British Columbia Ltd., 2018 FCA 166

Overturning the Tax Court of Canada’s (Tax Court) decision, the Federal Court of Appeal (FCA) ruled in 594710 British Columbia Ltd that GAAR is applicable in a loss utilization strategy where a new partner (Nuinsco) with a significant unused loss balance entered a partnership to facilitate an allocation of virtually all the partnership’s income, availing the former […]

The Federal Court of Appeal Applies GAAR in a Partnership Loss Transfer Strategy: Canada v. 594710 British Columbia Ltd., 2018 FCA 166 Read More »

The Federal Court of Appeal Applies GAAR in a Partnership Loss Transfer Strategy: Canada v. 594710 British Columbia Ltd., 2018 FCA 166

Overturning the Tax Court of Canada’s (Tax Court) decision, the Federal Court of Appeal (FCA) ruled in 594710 British Columbia Ltd that GAAR is applicable in a loss utilization strategy where a new partner (Nuinsco) with a significant unused loss balance entered a partnership to facilitate an allocation of virtually all the partnership’s income, availing the former

The Federal Court of Appeal Applies GAAR in a Partnership Loss Transfer Strategy: Canada v. 594710 British Columbia Ltd., 2018 FCA 166 Read More »

IT231R2- Partnerships – Partners not dealing at arm’s length

NO: IT-231R2 DATE: March 3, 1986 SUBJECT: INCOME TAX ACT Partnerships – Partners not Dealing at Arm’s Length REFERENCE: Subsection 103(1.1) IT231R2 Partnerships – Partners not dealing at arm’s length This bulletin replaces and cancels Interpretation Bulletin IT-231R dated November 21, 1977. 1. This bulletin discusses the sharing of income from partnerships by partners who do

IT231R2- Partnerships – Partners not dealing at arm’s length Read More »

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