Joel Nitikman, "Is an LLP a Corporation for Canadian Tax Purposes? A Reply to the CRA", Tax Topics (Wolters Kluwer), No. 2313, July 7, 2016, p.1.

Summary Under
Tax Topics - Income Tax Act - Section 96

Partnership and corporation based on contract and statute, respectively (p. 4)

There is a fundamental aspect of corporations that partnerships do...

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Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation

Conclusion that an LLLP or LLP is a partnership for ITA purposes given that has the following hallmarks of partnership:

(a) it has at least two...

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