SIFT Partnership definition

SIFT Partnership means a specified investment flow-through partnership for the purposes of the Tax Act.
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SIFT Partnership means a partnership to which the SIFT Rules apply. “SIFT trust” means a trust to which the SIFT Rules apply.
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SIFT Partnership means a "SIFT partnership" as that term is defined in subsection 197(1) of the Tax Act.49
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Examples of SIFT Partnership in a sentence

  • As discussed above under Item 6.1 Status of the Trust The SIFT Rules, the SIFT Rules apply an entity level tax on certain income (other than taxable dividends) earned by a SIFT Partnership and treat the distribution of such income received partners of a SIFT Partnership as taxable dividends received by from a taxable Canadian corporation.

  • Also, one of the partnership within the Trust’s organization would be a SIFT Partnership and therefore subject to tax under the SIFT rules.

  • If the SIFT Partnership rules are not amended, or alternatively, the Trust does not take steps to ensure that the particular partnership is not considered a SIFT partnership, non- portfolio earnings of the partnership in subsequent years will be subject to tax.


More Definitions of SIFT Partnership

SIFT Partnership means a partnership as defined in section 197 of the Tax Act; (ttt) “SIFT trust” means a trust as defined in section 122.1 of the Tax Act;
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Related to SIFT Partnership

  • General partnership means an organization formed under chapters 45-13 through 45-21.

  • Operating Partnership has the meaning set forth in the preamble.

  • Foreign limited partnership means a partnership formed under laws other than of this state and having as partners one or more general partners and one or more limited partners.

  • Public-private partnership means an arrangement or agreement, occurring on or after January 1, 2017, between a procurement unit and one or more contractors to provide for a public need through the development or operation of a project in which the contractor or

  • Limited partnership means a limited partnership registered or formed under any law in force in Singapore or elsewhere;

  • GP means Gottbetter & Partners, LLP.

  • REIT means a real estate investment trust under Sections 856 through 860 of the Code.

  • General Partnership Interest means a Partnership Interest held by the General Partner that is a general partnership interest.

  • General Partner means the general partner of the Partnership.

  • Limited liability partnership or “LLP” shall mean a Company governed by Limited Liability Partnership Act 2008 or as amended;

  • Borrower Partnership Agreement means the Limited Partnership Agreement of the Borrower dated as of January 17, 2014 as such agreement may be amended, restated, modified or supplemented from time to time with the consent of the Administrative Agent or as permitted under Section 10.10.

  • MLP Partnership Agreement means the Amended and Restated Agreement of Limited Partnership of the MLP, as amended or restated from time to time.

  • Foreign partnership means an association of two or more persons to carry on as co-owners of a

  • Partnership has the meaning set forth in the Preamble.

  • Partnership Subsidiary means Host LP and any partnership, limited liability company, or other entity treated as a partnership for federal income tax purposes or disregarded as a separate entity for federal income tax purposes in which either Host REIT or Host LP owns (or owned on or after January 1, 1999) an interest, either directly or through one or more other partnerships, limited liability companies or other entities treated as a partnership for federal income tax purposes or disregarded as a separate entity for federal income tax purposes (whether or not Host REIT or Host LP has a controlling interest in, or otherwise has the ability to control or direct the operation of, such entity). Notwithstanding the foregoing, the term “Partnership Subsidiary” shall not in any way be deemed to include the Non-Controlled Subsidiaries or subsidiaries thereof, the Taxable REIT Subsidiaries or subsidiaries thereof, or the Subsidiary REITs or subsidiaries thereof.

  • Limited Partnership Interest means the ownership interest of a Limited Partner in the Partnership at any particular time, including the right of such Limited Partner to any and all benefits to which such Limited Partner may be entitled as provided in this Agreement and in the Act, together with the obligations of such Limited Partner to comply with all the provisions of this Agreement and of the Act.

  • Disqualified Partnership Any domestic entity classified as a partnership under the Code if any of its direct or indirect beneficial owners (other than through a U.S. corporation) are (or, under the applicable partnership agreement, are permitted to be) Disqualified Non-United States Tax Persons.

  • Surviving Partnership has the meaning set forth in Section 11.2.B(ii) hereof.

  • Foreign limited liability partnership means a partnership that:

  • LP means the aggregate quantity of Lost Production during such Month (expressed in MWh) and

  • Foreign limited liability limited partnership means a foreign limited partnership whose general partners have limited liability for the obligations of the foreign limited partnership under a provision similar to section 488.404, subsection 3.

  • Operating Company means an “operating company” within the meaning of 29 C.F.R. §2510.3-101(c) of the Plan Asset Regulations.

  • Limited Partnership Agreement means the Amended and Restated Agreement of Limited Partnership of the Partnership dated as of March 1, 2017, as amended, supplemented or restated from time to time.

  • Subsidiary Partnership means any partnership of which the partnership interests therein are owned by the General Partner or a direct or indirect subsidiary of the General Partner.

  • Atlas means Automated Transportation Logistics Activity System. ATLAS is a computerized information system to which all Shippers have access upon request. ATLAS enables Shippers to nominate and release product and to monitor and coordinate the movement of Petroleum Products while on Carrier's system.

  • Public-private partnership agreement means an agreement