11 February 2020

Canada's investment limited partnerships face SLFI compliance obligations

The Selected Listed Financial Institution (SLFI) rules were extended to investment limited partnerships (ILPs) effective January 1, 2019. These rules aim to put ILPs on the same playing field as other investment structures such as mutual funds, which pay GST/HST and QST at a rate determined in accordance with the residency of their investors. An ILP is therefore required to determine its net tax liability/refund pursuant to the special attribution method formula (SAM formula). The SAM formula includes the provincial attribution percentage (PAP) calculation, which, in the case of an ILP, is determined on the basis of the residency of the unitholders. An ILP that qualifies as a SLFI must report the resulting GST/HST and QST net tax liability/refund using the prescribed return (SLFI Return). The SLFI return for the 2019 year must be filed by June 30, 2020.

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

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Full text of this Tax Alert

Document ID: 2020-0338