CRA announces that it will entertain submissions for LLPs and LLLPs to file as corps only on a going-forward basis

Where a Florida or Delaware LLP and LLLP is precluded from converting to a “true” partnership, CRA will entertain submissions to allow it to file as a corporation on a going-forward basis while leaving the previous years’ filings unchanged. CRA will review such submissions to see that there is no unwarranted benefit or undue tax advantage, including a review of the relevant tax attributes.

Neal Armstrong. Summary of 29 November 2016 CTF Annual Roundtable, Q.10 under s. 96.