GST/HST Memorandum 14-8 Closely Related Canadian Partnerships and Corporations for Purposes of Section 156 June 2023

S. 156(1.3)(b)(i) tests applied on a source-by-source basis

9. The income entitlement part [in s. 156(1.3)(b)(i)] recognizes the fact that a...

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Test in s. 156(1.3)(b)(iii) precludes a limited partner as such being closely related to the partnership

12. In a limited partnership, the limited...

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3 stacked Canadian partnerships, which thus form a closely related group, are closely related to a 4^th Canadian partnership jointly owned by them

By virtue of a qualifying group – consisting of a holding partnership (X) holding 90% of a partnership (Y) and 90% of a corporation (Z) – each...

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Where 2 grandchildren of AB Corp each hold a 50% partnership interest in XY, each corporation in that chain, as well as each corporation in...

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