An LLC election to be fiscally regarded does not trigger a disposition
11 June 2018 - 12:15am
CRA confirmed that an election by a disregarded LLC to be regarded for US tax purposes would not result in a disposition of either the units held in the LLC by its members or of the LLC’s assets for Canadian purposes.
Neal Armstrong. Summary of 29 May 2018 STEP Roundtable Q.16 under s. 248(1) – disposition.