CRA finds that qualifying revenue of a partnership does not flow through to its partners for CEWS purposes

After quoting from the definition of “qualifying revenue” appearing in the CEWS (wage subsidy) rules, CRA stated:

[A] member's share of the profits of a partnership, as allocated to the member pursuant to subsection 96(1) and in accordance with the partnership agreement, is not "qualifying revenue" to the member … .

A second technical interpretation released at the same time essentially indicated that this conclusion did not change if the partner was a limited partner.

Although the point was not really discussed, it might turn on a partnership being an eligible entity for CEWS purposes, so that this interpretation need not imply that a partnership is not transparent in other contexts.

Neal Armstrong. Summary of 12 December 2022 External T.I. 2021-0878941E5 F under s. 125.7(1) – qualifying revenue and summary of 7 December 2022 External T.I. 2020-0846891E5 F under s. 125.7(7).