Subsection 5908(10)
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...
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...