CRA indicates that a corporate partner receives no ACB addition for a s. 34.2(2) stub period inclusion

CRA considers that an amount included in a corporation’s income under s. 34.2(2) will not be added to the adjusted cost base of its partnership interest. The reason is that s. 53(1)(e)(i) only boosts ACB for a pro rata share of income earned at the partnership level rather than (imputed) income earned directly by the partner.

Neal Armstrong. Summary of 10 May 2017 External T.I. 2017-0687051E5 Tr under s. 53(1)(e)(i).