10 July 1990 Income Tax Severed Letter ACC9452 - Capital Gains Exemption - Limited Partners Regarded as Carrying on an Active Business

By services, 22 July, 2022
Official title
Capital Gains Exemption - Limited Partners Regarded as Carrying on an Active Business
Language
English
Document number
Citation name
ACC9452
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
656379
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1990-07-10 08:00:00",
"field_tags": []
}
Main text
24(1)                         900922
                                     M. Eisner
                                     (613) 957-2138

Attention: 19(1)

JUL 10 1990

Dear Sirs:

This is in reply to your letter of May 9, 1990 concerning the limited partners of a partnership in relation to clause 110.6(14)(f)(ii)(B) of the Income Tax Act.

With respect to your concern, it is the department's general view that the limited partners would be regarded as carrying on an active business for the purposes of clause 110.6(14)(f)(ii)(B), provided the partnership itself is carrying on an active business.

These comments represent our opinion of the law as it applies generally. As indicated in paragraph 24 of Information Circular 70-6R dated December 18, 1978 this opinion is not a ruling and accordingly, it is not binding on Revenue Canada, Taxation.

We trust you will find the foregoing satisfactory.

Yours truly,

for Director Business and General Division Rulings Directorate Legislative and Intergovernmental Affairs Branch