CRA indicates that a corporation’s adjusted stub period accrual respecting a partnership cannot be reduced by s. 111(1)(e) losses

The adjusted stub period accrual (“ASPA”) of a corporation in respect of a partnership generally is reduced, under Element B of the formula for computing the ASPA, by the corporation's share of losses (or certain allowable capital losses) of the partnership for a fiscal period of the partnership that ends in the corporation’s current taxation year. CRA indicated that this means that the corporation cannot reduce its ASPA (and, therefore, the amount to be included in its income under s. 34.2(1)) by the amount of deductions in computing taxable income, such as s. 111(1)(e) limited partnership losses.

Neal Armstrong. Summary of 12 June 2020 External T.I. 2018-0788161E5 F under s. 34.2(1) - adjusted stub period accrual – (a) – B.