“After an analysis of the complexities for taxpayers and the tax administration of transition from partnership filings to corporate filings, the CRA has decided to build on the prospective approach referred to in the November 2016 CTF announcement by offering administrative grandfathering. In particular, the CRA will be adopting the administrative practice of allowing any such entity formed before April 26, 2017 to file as a partnership for all prior and future tax years, provided none of the following conditions applies: One or more members of the entity/and or the entity itself take inconsistent positions from one taxation year to another, or for the same taxation year, between partnership and corporate treatment;
There is a significant change in the membership and/or the activities of the entity; or
The entity is being used to facilitate abusive tax avoidance.”
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