CRA agrees to certify the status of a partnership as a Canadian partnership at the request of an authorized representative.
20 March 2015 - 11:33am
CRA has now agreed to be somewhat more accommodating of requests for a certificate of residency of a Canadian partnership (e.g., from the India tax authorities), stating that where a representative is authorized to act on behalf of all the partners, CRA, on request of that representative:
will certify the residency of all the partners of the partnership, and certify that the partnership is a "Canadian partnership."
It would not hurt to add a clause, to the boilerplate for an LP agreement, that the GP or its tax advisor is thereby authorized to seek a certificate of residency on behalf of all the partners.
Neal Armstrong. Summary of 26 January 2015 T.I. 2014-0547501E5 under s. 2(1).