Principal Issues: Whether the QTI reserve would be restricted in various scenarios as a result of the restriction in subparagraph 34.2(13)(c)(i), which applies if, in computing a corporate partner’s income for a taxation year in respect of a partnership, the year ends immediately before another taxation year “at the beginning of which the partnership no longer principally carries on the activities to which the reserve relates”
Position: General comments only.
Reasons: Question of fact