![]() Blood relationshipġ.3 Paragraph 251(6)(a) refers to a blood relationship as being that of: The reader should, therefore, consider such comments in light of the relevant provisions of the law in force for the particular tax year being considered.ġ.2 According to paragraph 251(2)(a), individuals connected by blood relationship, marriage, common-law partnership or adoption are related persons. While the comments in a particular paragraph in a folio may relate to provisions of the law in force at the time they were made, such comments are not a substitute for the law. ![]() Due to their technical nature, folios are used primarily by tax specialists and other individuals who have an interest in tax matters. The Canada Revenue Agency (CRA) issues income tax folios to provide technical interpretations and positions regarding certain provisions contained in income tax law. ![]() The second category refers specifically to certain personal trusts and their beneficiaries while the third category refers to all other persons not related to each other. The first category of persons is related persons and the second and third categories of persons are referred to in this Chapter as unrelated persons. Section 251, which is the statutory provision for determining arm's-length relationships, refers to three categories of persons. Although the term at arm's length is used throughout the Act, the Act does not contain any precise definition of the term. ![]() This Chapter discusses the criteria used to determine whether persons deal with each other at arm's length for purposes of the Act. ![]()
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