CRA indicates that a reporting-entity partnership with a partner related to other group members can qualify as a member of a related group for T1134-reduced reporting purposes

The T1134 instructions indicate that to access the relief for related reporting entities, they should be related as per s. 251(4). How is it determined whether a partnership is part of a related group for purposes of this relief?

After noting that a “partnership described in paragraph 233.4(1)(c) is a reporting entity for the purposes of section 233.4 as soon as a partner who is resident in Canada and who is not exempt from Part I tax has an interest of at least 10% in the income or losses of the partnership for the fiscal period,” CRA stated:

If a partnership is a reporting entity in respect of a foreign affiliate, the administrative relief for related reporting groups extends to the partnership if at least one of its members (or if another partnership is a member, one of its members) is related to each of the other reporting entities forming a related group in respect of that same foreign affiliate.

Neal Armstrong. Summary of 10 October 2024 APFF Roundtable, Q.5 under s. 233.4(4).