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25 May 2017

Law firm clients: Canada Revenue Agency extends transitional relief for certain US partnerships

We wanted to bring to your attention a recent development in Canada relevant to our law firm clients.

At a conference hosted by the International Fiscal Association (IFA) in Toronto on April 26, officials from the Canada Revenue Agency (CRA) provided clarification on transitional measures pertaining to the treatment of limited liability partnerships and limited liability limited partnerships (collectively, LLPs) as corporations for Canadian income tax purposes. In short, the CRA announced that it will generally consider LLPs formed under the laws of Delaware, Florida, or similar laws in the United States to be corporations for Canadian income tax purposes (consistent with prior positions). However, the CRA is prepared to accept LLPs formed prior to April 26 as partnerships for all prior and future years provided certain conditions are satisfied.

Please see the Global Tax Alert prepared by Ernst & Young Canada for further details.

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Contact Information
For additional information concerning this Alert, please contact:
 
Law Firm Industry Practice
• Shelby Saad-Callahan(617) 375-1237
International Tax Services
• Cindy Lin (212) 773-8057
• Shragi M Portal (212) 773-2955

Document ID: 2017-0866

 

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