CRA indicates that an Arizona limited partnership is a partnership rather than a corporation for ITA purposes

Two Arizona limited partnerships holding rental properties were to be treated as partnerships rather than corporations under the two-step approach of CRA to entity classification. Although they had separate legal personality, that by itself did not preclude them from being classified as partnerships. On the other hand, they had various attributes of common law partnerships including importantly, that the general partner had unlimited liability.

Neal Armstrong. Summary of 28 November 2024 Internal T.I. 2024-1014251I7 under s. 96.