Subsection 5000(1)
Administrative Policy
14 February 1994 Internal T.I. 5-933665
In response to an expressed concern that a trust or corporation could inadvertently have excess foreign property where it undertook to...
Subsection 5000(1.2)
Administrative Policy
14 November 1996 T.I. 963760 (C.T.O. Interest in Pooled Fund/Master Trust")
Where a pooled fund trust also is a master trust, an interest in the pooled fund trust will not be foreign property regardless of its status as a...
Subsection 5000(2)
Administrative Policy
1996 Ruling 961677 (C.T.O. "Swap Contract, Marketable Security")
The cost amount to a fund of its investments in exchange-traded futures contracts is equal to the brokerage fees and other costs incidental to...
Subsection 5000(7)
Pooled Fund Trust
Administrative Policy
31 May 1999 T.I. 990891
Where a trust is established with two trust companies, both trustees should qualify as a trust company incorporated under the laws of Canada or a...
1997 Ruling 3-971192
Favourable ruling given that a partnership that otherwise qualified as a qualified limited partnership would not cease to so qualify if it...
17 May 1995 T.I. 950389 (C.T.O. "Second Relevant Year for Pooled Fund Trust Tests")
General discussion of the addition of references to the "second relevant year".
18 April 1995 T.I. 950089 (C.T.O. "Pooled Fund Trusts")
The cost amount of a futures contract at the time it is entered into or acquired is equal to the brokerage fees and other costs incidental to...
10 February 1995 External T.I. 5-943179
"The term 'marketable security' refers generally to a security that is capable of reasonably prompt conversion into cash and that is easily...
6 October 1994 External T.I. 5-942074
"A Trust that is prescribed to be a master trust under section 5001 of the Income Tax Regulations ("Regulations") and that elects to be such a...
19 June 1992 External T.I. 5-921587
A unit which was acquired in a year throughout which the trust does not meet the required conditions will not be an interest in a pooled fund trust.
21 May 1991 T.I. (Tax Window, No. 3, p. 32, ¶1261)
The lending of qualified securities by a pooled fund trust as a result of a securities lending arrangement will constitute the investing of funds...
Articles
Krasa, "Income Tax Implications of Joint Investment by Pension Plans through a Private Pooled Fund Vehicle", 1997 Canadian Tax Journal, Vol. 45, No. 1, p. 1.
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| Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(o.4) | 0 |
Qualified Limited Partnership
Administrative Policy
2002 Ruling 2002-013816
The terms of the partnership agreement that provided that a limited partner would be excused or excluded from or to pay a particular investment...
2000 Ruling 1999-000857
An arrangement under which a general partner had the right to catch-up earnings after the limited partners were paid an initial return and before...
24 October 1996 T.I. 962987 (C.T.O. "30% Limited Partner Interests")
A limited partnership which is formed with one general and one nominee limited partner prior to a public offering will not qualify under...