Canada v. Green, 2017 FCA 107
| Court | Federal Court of Appeal (Canada) |
| Case Date | May 19, 2017 |
| Jurisdiction | Canada (Federal) |
| Citations | 2017 FCA 107 |
-
- This document is available in original version only for vLex customers
View this document and try vLex for 7 days - TRY VLEX
- This document is available in original version only for vLex customers
7 practice notes
-
Zeifmans LLP v. Canada (National Revenue), 2021 FC 363
...of a specific partner. Zeifmans submits that a partnership is not a person at law as reflected in section 96 of the ITA (Canada v Green, 2017 FCA 107 at para 5). As such, the RFI was not issued to a person and the Minister acted without jurisdiction. [69] The Minister submits that, by addre......
-
The Stikeman Elliott Federal Budget Commentary 2018
...can only be acquired through a prescription. Footnotes 1 "Balanced budget still within Trudeau's reach", Charles Lamman and Hugh 2 Ibid. 3 2017 FCA 107, aff'g 2016 TCC 10. 4 The deeming provision in subsection 102(2) of the ITA is still relevant as it applies to the entire subdivision j, Di......
-
Highlights Of The 2018 Federal Budget
...Day. At-Risk Rules for Tiered Partnerships In response to the recent Federal Court of Appeal decision in Canada v. Green, J.N. et al, 2017 FCA 107 ("Green"), Budget 2018 proposes to clarify that the at-risk rules apply to a partnership that is itself a limited partner of another partnership......
-
Budget 2018: Sensible Measures
...transparent overall system. AT-RISK RULES FOR TIERED PARTNERSHIPS In response to the Federal Court of Appeal's decision in Canada v Green, 2017 FCA 107, Budget 2018 provides technical amendments addressing limited partnership losses in the context of tiered partnership structures, i.e. wher......
Request a trial to view additional results
2 cases
-
Zeifmans LLP v. Canada (National Revenue), 2021 FC 363
...of a specific partner. Zeifmans submits that a partnership is not a person at law as reflected in section 96 of the ITA (Canada v Green, 2017 FCA 107 at para 5). As such, the RFI was not issued to a person and the Minister acted without jurisdiction. [69] The Minister submits that, by addre......
-
Aquilini (Estate) v. The Queen, 2019 TCC 132
...of AIGLP and hence clearly a member as well. It should be noted that the Appellants argue that based on the decision of Canada v. Green, 2017 FCA 107 and in particular referenced the dictum at paragraph 29 thereof: 29. Since the computation of income for a partnership that is a member of an......
5 firm's commentaries
-
The Stikeman Elliott Federal Budget Commentary 2018
...can only be acquired through a prescription. Footnotes 1 "Balanced budget still within Trudeau's reach", Charles Lamman and Hugh 2 Ibid. 3 2017 FCA 107, aff'g 2016 TCC 10. 4 The deeming provision in subsection 102(2) of the ITA is still relevant as it applies to the entire subdivision j, Di......
-
Highlights Of The 2018 Federal Budget
...Day. At-Risk Rules for Tiered Partnerships In response to the recent Federal Court of Appeal decision in Canada v. Green, J.N. et al, 2017 FCA 107 ("Green"), Budget 2018 proposes to clarify that the at-risk rules apply to a partnership that is itself a limited partner of another partnership......
-
Budget 2018: Sensible Measures
...transparent overall system. AT-RISK RULES FOR TIERED PARTNERSHIPS In response to the Federal Court of Appeal's decision in Canada v Green, 2017 FCA 107, Budget 2018 provides technical amendments addressing limited partnership losses in the context of tiered partnership structures, i.e. wher......
-
Highlights Of Canada's 2018 Federal Budget
...are not eligible to be carried forward by such limited partners. However, a recent Federal Court of Appeal decision (Canada v. Green, 2017 FCA 107) constrained the application of the at-risk rules in tiered partnership structures in a manner that, according to Finance, is inconsistent with ......
Request a trial to view additional results