CRA confirms that a non-statute-barred partner can be assessed directly where the s. 152(1.4) partnership loss determination period is exceeded

CRA confirmed (consistently with comments in 2078970 Ontario) that if it has not made a partnership loss determination within the three-year limitation period under s. 152(1.4), it has the option of assessing the partners directly where their returns are not yet statute-barred.

Neal Armstrong. Summary of 17 April 2018 Internal T.I. 2017-0734751I7 under s. 152(1.4).