IT-81R "Partnerships - Income of Non-Resident Partners"

Income that becomes subject to Part I as a result of an s. 216 election is not considered to be earned in any particular province.

Each partner is the agent of the other partners and hence, although a partner may not himself actively participate in the business of the...

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No withholding-reduction based on Cdn-resident members

7. ...Where tax is to be withheld under Part XIII because a partnership is deemed by...

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A non-resident corporation which is a member of a partnership carrying on business in Canada is subject to the branch tax.