CRA acknowledges that it cannot make a partnership income or loss determination where the partnership has no T5013 filing obligation

CRA’s position is that where the partners of a partnership are not required to file a T5013 (which would generally be the case if the partnership does not carry on a business in Canada, and is not a Canadian partnership or SIFT partnership), CRA cannot make a partnership income or loss determination under s. 152(1.4). Instead, if CRA considers the partnership income or loss reported by a partner to be incorrect, it will assess the partner directly subject to the normal limitations under the general rules in s. 152(4). See also 2078970 Ontario and 2017-0734751I7.

Neal Armstrong. Summary of 5 October 2018 APFF Roundtable, Q.6 under s. 152(1.4).