The inconsistent treatment of partnerships in the  Income Tax Act.
Published: 2004
Language: eng
Number of pages: 129
Subjects: University of Toronto. -- Faculty of Law -- Dissertations.; Canada.; Partnership -- Taxation -- Canada.; Income tax -- Law and legislation -- Canada.
Description: The ancillary objectives of the Income Tax Act are equity, neutrality and simplicity. A mutual characteristic of these objectives is consistency. If provisions of the Income Tax Act are consistent, they will support the system's objectives and strengthen the income tax system.This thesis will analyze the inconsistencies in the structure of partnership taxation and discuss how they breach the objectives of the Income Tax Act. Recommendations to improve the taxation of partnerships structure are also presented.Partnerships, however, are treated inconsistently in the Income Tax Act. Income tax law relies on general partnership law when applying tax law principles. However, there are instances where the Income Tax Act deviates from general partnership law. Also, there are instances where general partnership law is conflicting. As well, there are instances in the Income Tax Act where partnerships and corporations are treated differently in the same situation with no supporting policy reason.
Notes: Adviser: David Stevens.

Thesis (LL.M.)--University of Toronto, 2004.

Electronic version licensed for access by U. of T. users.

Source: Masters Abstracts International, Volume: 43-03, page: 0723.

MICR copy on microfiche (2 microfiches).