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September 22, 2016
2016-1601

Canada Revenue Agency treats certain US partnerships as corporations

At a May 26 conference in Montreal hosted by the International Fiscal Association (IFA), representatives from the Canada Revenue Agency (CRA) announced that the CRA will consider limited liability partnerships and limited liability limited partnerships (collectively, LLPs) established under Delaware and Florida law to be corporations for Canadian income tax purposes. The consequences are that these LLPs will be considered separate legal entities for tax purposes, taxable at the entity level rather than at the partner level.

A Tax Alert prepared by Ernst & Young Canada, and attached below, provides additional details.

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Full text of Tax Alert 2016-1601

 

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