Concurrent small LP investments of a sister-in-law can convert small shareholdings in Canadian resource companies into taxable Canadian property

Under the July 12, 2013 draft amendments, a small shareholding in a Canadian resource or real estate company will be taxable Canadian property if the same non-resident investor, or a non-arm's length person, also held units of various partnerships which, in aggregate had 25% (or close to 25%) of the shares of the same company - and similarly for income funds or REITs.

There will be expansions to the standard jello jiggler circular disclosure for non-residents.

Neal Armstrong.  Summary of Jack Bernstein and Francesco Gucciardo, "TCP Proposal Overshoots Objective?", Canadian Tax Highlights, Vol. 21, No. 8, p. 4 under s. 248(1) - taxable Canadian property.