What is a Partnership for Tax Purposes?
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...
At-Risk Amount Rules & Partnerships
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...