CRA’s new position on US LLLPs and LLPs

On May 26, 2016, the Canada Revenue Agency (CRA) announced that it will consider Florida and Delaware limited liability limited partnerships (LLLPs) and US limited liability partnerships (LLPs) to be corporations for Canadian tax purposes. Presumably, other LLPs and LLLPs will be treated similarly. Recently, US LLLPs and LLPs have been used by Canadians as a common structure for investing in US real estate. The CRA’s new administrative position may make investments into US LLLPs or LLPs by Canadians unattractive, and may require additional planning for those who currently hold an interest in a US LLLP or LLP.

Find out more about the CRA's new position on US LLLPs and LLPs. [ 85 kb ]