CRA indicates that a partner assignment of its specified partnership business limit may be amended within the statute-barring period

CRA confirmed that its position - that an associated group of Canadian-controlled private corporations can file amended T2 Schedule 23s providing an amended business limit allocation agreement provided that this does not change the amount allocated to any associated corporation for a taxation year for which a reassessment is statute-barred – also essentially applies to an amended assignment of a partner’s specified partnership business limit.

Neal Armstrong. Summary of 5 April 2018 Internal T.I. 2017-0728581I7 under s. 125(3.2)(d) and s. 125(8)(c).