Partnerships

Tiered Partnerships & Flow-Through Characteristics A tiered or stacked partnership refers to a partnership that owns a partnership interest in another partnership. The Tax Court of Canada (TCC) affirmed the flow-through characteristics of income and losses through a tiered partnership structure in the decision in Devon...

Partnerships and Tax Law A Combination of Legislation and Common Law As outlined in the decision of the Supreme Court of Canada (SCC) in Continental Bank Leasing Corp. v. Canada, 1998 CanLII 794 (SCC), 2 SCR 298, the law relevant to the taxation of partnerships is drawn from...

Limited Partnership Tax Shelters & At-Risk Rules What are the At-Risk Rules? The at-risk amount rules (at-risk rules) are used by Canada Revenue Agency (“CRA”) to counter the abusive deduction of partnership losses.Limited partnerships are commonly utilized in tax shelter...