Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 07 MAY 2019

ILP, SLFI, HST – Tax Acronyms Every Fund Should Know

Norton Rose Fulbright Canada LLP
Explore more from Norton Rose Fulbright Canada LLP

What we often don't do, however, is consider the GST/HST implications

CanadaTax
Author LinkedIn connections

When we structure private equity funds, whether through a mutual fund trust, limited partnership or certain other entities, considerable time is spent on the income tax issues. We examine the deductibility of the management fees. We consider strategies for delivering the carried interest to employees in a tax-efficient way. We take steps to keep the flow-through nature of the mutual fund trust and prevent it from being a SIFT trust. We draft detailed securities tax disclosure dealing with allocation and distribution of earnings to unitholders, the resulting impact on adjusted cost base and the tax consequences of redemption of units, among other issues.

What we often don't do, however, is consider the GST/HST implications. At first glance, this makes sense, as the only sales private equity funds usually make are sales of trust or partnership units (or shares of a corporation). The fund's income is generally derived from interest or dividends. All of these are exempt

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in
About Norton Rose Fulbright Canada LLP

Norton Rose Fulbright is a global law firm. We provide the world's preeminent corporations and financial institutions with a full business law service. We have 3800 lawyers and other legal staff based in more than 50 cities across Europe, the United States, Canada, Latin America, Asia, Australia, Africa, the Middle East and Central Asia.

Recognized for our industry focus, we are strong across all the key industry sectors: financial institutions; energy; infrastructure, mining and commodities; transport; technology and innovation; and life sciences and healthcare.

Wherever we are, we operate in accordance with our global business principles of quality, unity and integrity. We aim to provide the highest possible standard of legal service in each of our offices and to maintain that level of quality at every point of contact.

For more information about Norton Rose Fulbright, see nortonrosefulbright.com/legal-notices.

Law around the world
nortonrosefulbright.com

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

Cryptocurrency Held Through A Bare Trustee: Tax Treatment And The 2026 Reporting Obligations

If you hold cryptocurrency, NFTs or other blockchain assets in someone else’s wallet, or hold assets in your own wallet for someone else, the arrangement is very likely a bare trust. Until recently, that carried almost no compliance consequence. It now carries three reporting obligations to track: the T3 filing for 2026, the T1135, and the proposed Crypto-Asset Reporting Framework from 2027.
CanadaTax
Rotfleisch & Samulovitch P.C.
Rotfleisch & Samulovitch P.C.
Article

How To Appeal The Toronto Vacant Home (VHT) Tax: Here’s What One Landlord Did To Fight VHT Assessment

Since 2022, the City of Toronto has imposed an annual Vacant Home Tax (VHT) on residential units left unoccupied for more than six months of the year. For most owners the tax is an afterthought: file the annual declaration, confirm the unit was lived in, and move on. But when the City’s administrative process breaks down, an owner can find themselves fighting a five-figure tax bill over a unit they insist was never vacant at all.
CanadaTax
Rotfleisch & Samulovitch P.C.
Rotfleisch & Samulovitch P.C.
Article

Canadian Prime Minister Announces ‘Productivity Mega Deduction’

Canada's new Productivity Mega Deduction permanently provides immediate expensing for a wide range of depreciable property and Canadian development expenses, dramatically expanding the scope beyond the previously announced Productivity Super Deduction. The measure aims to reduce Canada's marginal effective tax rate on new business investment to 6.4%, positioning it as the lowest among major economies and less than half the U.S. rate.
CanadaTax
Osler, Hoskin & Harcourt LLP
Osler, Hoskin & Harcourt LLP
Article

Productivity Mega Deduction: Key Tax Measures Announced At The Canada Investment Summit

Canada has introduced a permanent Productivity Mega Deduction allowing immediate expensing of up to 100% of eligible capital property costs and Canadian development expenses acquired after September 15, 2026. This measure aims to boost business investment and strengthen Canada's tax competitiveness by expanding immediate expensing eligibility from 15% to approximately two-thirds of capital investments, while reducing the country's marginal effective tax rate to 6.4%.
CanadaTax
McCarthy Tétrault
McCarthy Tétrault