Open AccessIncome Tax Considerations Affecting the Drilling Fund - A Practitioner's Viewpoint
Author(s) -
Michael A. Carten
Publication year - 1978
Publication title -
alberta law review
Language(s) - English
Resource type - Journals
eISSN - 1925-8356
pISSN - 0002-4821
DOI - 10.29173/alr595
Subject(s) - structuring , general partnership , limited partnership , revenue , income tax , business , public economics , economics , tax deduction , tax revenue , finance , state income tax , tax reform , gross income
The author reviews federal income tax considerations involved in structuring drilling fund, particularly where the organizational form is the limited partnership. He discusses classification, allocation and deduction of partnership costs, including management and other fees; the use ofpartnership borrowings; factors to take into account in timing particular deductions; and the requirements for disclosure of tax consequences in drilling fund offering Practices and policies of Revenue Canada are referred to throughout the paper.