See Also
Anson v. HMRC, [2015] UKSC 44
Lord Reed found that that the profits of a Delaware LLC belonged to the members as they arose, so that a UK member was taxed on the "same" income...
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| Tax Topics - Treaties - Income Tax Conventions - Article 24 | UK LLC member had a personal (non-proprietary) entitlement to his share of LLC profits as they arose | 485 |
| Tax Topics - Treaties - Income Tax Conventions - Article 3 | scheme in Treaty article for allocating income between jurisdictions amounted to a definition of "source" | 88 |
| Tax Topics - Treaties - Income Tax Conventions - Article 4 | pragmatic approach to determining "same" - also appearing in IV,7(b) of Cda-US Treaty | 142 |
HMRC v. Anson, [2013] EWCA Civ 63, rev'd supra
The taxpayer, who was resident in the UK, paid US income taxes on his share of the profits of an LLC of which he was a member, and also paid UK...
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| Tax Topics - Treaties - Income Tax Conventions - Article 24 | LLC not transparent | 437 |
Hague v. Cancer Relief & Research Institute, [1939] 4 DLR 191 (Man. K.B.)
In finding that an institute which section 2 of the Cancer Relief Act, 1930 (Manitoba) purported to make a "body corporate" was not, in fact, a...
Administrative Policy
17 May 2022 IFA Roundtable Q. 8, 2022-0926431C6 - Foreign Entity Classification
Given the recent CRA' announcements on US LLLP classification and the introduction of anti-hybrid mismatch rules in countries like Luxembourg,...
27 October 2020 CTF Roundtable Q. 9, 2020-0866671C6 - entity classification of UK LLP
Under the UK’s Limited Liability Partnerships Act 2000, a limited liability partnership (“UK LLP”) is treated in the UK as a separate legal...
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| Tax Topics - Income Tax Act - Section 96 | UK LLP has the attributes of a corporation rather than a partnership | 107 |
1 August 2019 External T.I. 2018-0768561E5 - Application Administrative Position on US LLPs & LLLP
2017-0691131C6 stated that one of the conditions for allowing Delaware or Florida LLLPs formed before April 26, 2017 to file as a partnership was...
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| Tax Topics - Income Tax Act - Section 96 | no ability for an otherwise grandfathered LLLP to treat itself prospectively as a corporation | 216 |
16 May 2018 IFA Roundtable Q. 8, 2018-0749481C6 - Update on Entity Classification
CRA also declined to rule that a specific French SLP (Société de Libre Partenariat) that was a société en commandite simple was a partnership...
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| Tax Topics - Income Tax Act - Section 96 | French limited partnership viewed as corp/grandfathering relief re LLPs/LLLPs | 327 |
13 February 2017 Internal T.I. 2015-0568011I7 - Classification of Florida LLLP
After providing a detailed description of the relevant provisions of the Florida Revised Uniform Limited Partnership Act of 2005 respecting LLLPs,...
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| Tax Topics - Income Tax Act - Section 96 | Florida real estate LLLPs were corporations (subject to transitional relief) | 477 |
13 February 2017 Internal T.I. 2015-0587691I7 - Classification of a Delaware LLLP
A secondary assessing position of a TSO was that a Delaware LLLP, which had been wound-up, had been a corporation for ITA purposes. In the course...
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| Tax Topics - Income Tax Act - Section 96 | Delaware LLLP that was wound up before 2016 treated as partnership for capital loss purposes | 402 |
26 April 2017 IFA Roundtable Q. 3, 2017-0691131C6 - U.S. LLPs and LLLPs
CRA further extended its grandfathering relief from its view of Florida and Delaware LLPs and LLLPs as corporations, so that any such entities...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 96 | further extension of grandfathering relief for Florida and Delaware LLPs and LLLPs | 182 |
| Tax Topics - Treaties - Income Tax Conventions - Article 4 | Florida and Delaware LLPs and LLLPs treated like LLCs | 28 |
| Tax Topics - Income Tax Act - Section 93.2 - Subsection 93.2(2) | Florida and Delaware LLPs and LLLPs subject to s. 93.2 | 23 |
29 November 2016 CTF Roundtable Q. 10, 2016-0669751C6 - U.S. LLPs and LLLPs
Where a Florida or Delaware LLP and LLLP is precluded from converting to a “true” partnership, CRA will entertain submissions to allow it to...
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| Tax Topics - Income Tax Act - Section 96 | CRA may allow LLPs and LLLPs to file as corps only on a going-forward basis | 157 |
1 December 2015 Internal T.I. 2015-0588381I7 F - Classification of US-LLCs
A Quebec individual resident was a member of Delaware, New York and Florida LLCs. His representatives submitted that in light of Backman and the...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 96 | corporation/partnership classification of foreign entity not affected by Quebec residence of member | 233 |
| Tax Topics - Statutory Interpretation - Interpretation Act - Section 8.1 | 8.1 effected no change/2 step-approach should be inter-provincial | 277 |
2016 Ruling 2015-0571441R3 - Dutch Cooperative - 93.2 & 95(2)(c)
Before ruling that the contribution of shares of a Netherlands private limited liability company to a newly-formed Netherlands cooperative (Dutch...
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| Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(c) | rollover is available on joint drop-down of shares of a Dutch private limited liability company into a Dutch cooperative in consideration for respective credits to the membership accounts | 502 |
| Tax Topics - Income Tax Act - Section 93.2 - Subsection 93.2(2) | membership interest in Dutch cooperative ruled to be shares | 92 |
| Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Controlled Foreign Affiliate | non-resident subsidiaries CFAs of bottom-tier Cdn partnership and FAs of Canadian corporate partners | 130 |
| Tax Topics - Income Tax Act - Section 85.1 - Subsection 85.1(3) | joint contribution of shares of FA to Netherlands co-op in consideration for credits to their respective membership accounts deemed to be for share consideration | 57 |
21 June 2016 Internal T.I. 2015-0581151I7 - Dutch Co-Op Entity Classification
A taxpayer holds an interest in a Dutch Co-Op. Is it a partnership or a corporation? After referring to the two-step approach to entity...
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| Tax Topics - Income Tax Act - Section 96 | Dutch co-op a corp., not partnership | 45 |
| Tax Topics - General Concepts - Foreign Law | two-step approach applied to finding Dutch co-op a corporation | 103 |
10 June 2016 STEP Roundtable Q. 8, 2016-0634951C6 - U.S. LLPs & LLLPs Classification
CRA largely repeated its position immediately below in 2016 IFA Roundtable, Q. 1 (as well as indicating that Anson has not changed its views on...
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| Tax Topics - Income Tax Act - Section 96 | facts and circumstances test respecting transition of LLPs to corporation status | 160 |
29 April 2015 External T.I. 2014-0532691E5 F - Vente immeuble - syndicat copropriétaire
A syndicate of co-owners holding condominium units sold one of the condominiums at a capital gain and distributed the gain to its members. CRA...
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| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | distribution of gain to members of a condominium syndicate gave rise to a shareholder benefit | 77 |
| Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(l) | a syndicate of condominium co-owners could qualify as a s. 149(1)(l) corporation, so that a capital gain realized by it on a condo sale would be exempt | 151 |
2015 Ruling 2014-0541951R3 - Foreign Affiliate Debt Dumping
A (presumably U.S.) limited liability partnership (FA1) will pay a distribution proportionately to its partners who directly comprise (i) a...
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| Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(9) - Paragraph 212.3(9)(b) - Subparagraph 212.3(9)(b)(ii) | s. 212.3(9)(b)(ii) PUC restoration for upper-tier QSCs on the payment by a U.S. LLP of a proportionate “dividend” to lower tier CRIC partners | 349 |
| Tax Topics - Income Tax Act - Section 90 - Subsection 90(2) | proportionate LLP distribution to three direct or indirect general or limited partners treated as dividend on single class of shares | 110 |
| Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(3) | two Canadian corporate partners immediately beneath the U.S. border are QSCs respecting investments made by lower-tier CRICs in a U.S. LLP | 238 |
21 July 2017 External T.I. - General answer for Delaware/Florida Working Group Submissions / Questions
At the 2017 IFA Roundtable, CRA announced that it will allow Delaware & Florida LLPs and LLLPs formed before April 26, 2017 to continue filing as...
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| Tax Topics - Income Tax Act - Section 96 | CRA elaborates on its grandfathering of LLPs and LLLPs | 276 |
26 May 2016 IFA Roundtable Q. 1, 2016-0642051C6 - Classification of U.S. LLPs & LLLPs
CRA indicated that it has finalized its view that Florida and Delaware limited liability partnerships and limited liability limited partnerships...
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| Tax Topics - Income Tax Act - Section 96 | LLPs and LLLPs treated as corporations | 341 |
4 October 2010 Internal T.I. 2008-0289461I7 - Netherlands Antilles private foundation
Although a Netherlands Antilles private foundation had separate legal personality (including a separate legal entity clause in the governing...
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| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(1) | Netherlands Antilles private foundation qualifies as trust notwithstanding separate legal personality | 394 |
24 November CTF Annual Roundtable, Q.7
CRA was "heavily leaning" towards characterizing Florida limited liability partnerships (LLPs) and Florida limited liability limited partnerships...
20 August 2015 External T.I. 2015-0581681E5 F - Non-resident trust rules
CRA affirmed its position that a Liechtenstein Foundation "generally will be considered to be a trust for purposes of the Act." See summary under
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| Tax Topics - Income Tax Act - Section 94 - Subsection 94(1) - Connected Contributor | Liechtenstein Foundation with Canadian-resident beneficiary not subject to s. 94(3) | 343 |
[U.K] Revenue and Customs Brief 15 (2015): HMRC response to the Supreme Court decision in George Anson v HMRC (2015) UKSC 44 25 September 2015
…[T]he [Anson] decision is specific to the facts found in the case. This means that where US LLCs have been treated as companies within a group...
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| Tax Topics - Treaties - Income Tax Conventions - Article 24 | Anson specific to its facts | 112 |
INTM180030 - "Foreign entity classification for UK tax purposes: List of Classifications of Foreign Entities for UK tax purposes"
Country-by-country listing of entities as transparent or opaque for U.K. income tax purposes.
28 May 2015 IFA Roundtable Q. 3, 2015-0581511C6 - IFA 2015 Q.3: Entity Classification
CRA indicated that Florida limited liability limited partnerships and limited liability partnerships potentially may be corporations for purposes...
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| Tax Topics - Income Tax Act - Section 96 | status of LLLPs as partnerships or corporations | 402 |
30 October 2012 Ontario CTF Roundtable, 2012-0463021C6 - Directorate policy - entity classification
[The] Directorate has reconsidered its 2010 decision [to cease giving entity classification rulings]....Taxpayers wishing to request an advance...
5 October 2012 Roundtable, 2012-0451261C6 F - Foreign entity classification
What criteria does CRA apply characterizing a foreign entity, that has issued a security held by a Canadian resident, as a corporation, trust,...
15 July 2011 Internal T.I. 2010-0388621I7 - Entity Classification - Liechtenstein Anstalt
a Liechtenstein anstalt possessed most of the hallmarks of a corporation aside from issuing shares, and was to be treated as a corporation. ...
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Share | division of capital not necessary for "shares" | 136 |
| Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Foreign Affiliate | 140 |
14 April 2010 Internal T.I. 2009-0347511I7 F - Partie I.3 - Société de personnes
CRA found that in light of the definition of corporation in the French version of the Act and that the Quebec government was a legal person, the...
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| Tax Topics - Income Tax Act - Section 181.2 - Subsection 181.2(3) - Paragraph 181.2(3)(g) | s. 181.2(3)(g) was to be applied on basis that partnership interest and debt held by a Crown agent was held by the Quebec government, being a corporation | 158 |
28 September 2009 Internal T.I. 2008-0300511I7 - Classification of a foreign entity - Anstalt
In light of its characteristics, a Liechtenstein anstalt could be treated for Canadian purposes as either a trust or a corporation depending on...
Income Tax Technical News, No. 38, 22 September 2008 under "Foreign Entity Classification"
discussion of CRA's two-step approach to entity classification (determine its characteristics under the foreign law; and compare those...
14 August 2008 External T.I. 2004-0104691E5 - Conversion of a LLC to a LP
Application of CRA's two-step approach to entity classification resulted in a finding that a Delaware LLC governed by the Delaware Limited...
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| Tax Topics - Income Tax Act - Section 88 - Subsection 88(3) | 54 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | LLC conversion to Delaware LP | 54 |
5 October 2004 External T.I. 2004-0061861E5 - Status of a Malagasy SARL
A limited liability company organized in Madagascar would be considered to be a corporation for purposes of the Act given that it has several...
27 March 2008 External T.I. 2006-0200451E5 F - Syndicat de copropriétaires
Under article 1039 of the Civil Code, a community of co-owners of an immovable held in divided co-ownership constitutes a legal person, called a...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(l) | distribution of land by Quebec condominium syndicate would cause it to lose its NPO status | 65 |
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | the co-owners of a Quebec syndicate were to be viewed as members of a corporation, so that s. 15(1) applied to a distribution to them | 83 |
22 July 2003 Internal T.I. 2003-0018027 F - Fondation du Liechtenstein
Mr. X formed a foundation (a “sifting”) under the laws of Liechtenstein, of which he was the life beneficiary, and his wife and children were...
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| Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Controlled Foreign Affiliate | Liechtenstein sifting in which the resident individual had a life interest was to be treated as a 100% CFA | 243 |
| Tax Topics - Income Tax Act - Section 94 - Subsection 94(3) | Liechtenstein siftung was corporation, not trust | 79 |
9 September 2002 Internal T.I. 2002-0143957 - Liechtenstein Establ.- whether corporation
A Leichtenstein establishment (i.e., a Leichtenstein anstalt) is a corporation for purposes of the Act.
29 January 2002 External T.I. 2001-0085845 - Limited Liability Company
List of states for which CCRA has provided an opinion that a limited liability company formed under the laws of that state is a corporation for...
10 February 1999 External T.I. 9829875 - WHETHER HUNGARIAN KFT IS A CORPORATION
A Hungarian korlatolt feleossegu tarsasag is a corporation for purposes of the Act because it has legal personality and existence apart from its...
24 September 1997 External T.I. 9642195 - TENNESSEE LLC (CORPORATE STATUS?)
A Tennessee limited liability company is a corporation for purposes of the Act.
28 January 1997 External T.I. 9625015 - JOINT STOCK COMPANIES IN RUSSIA
A Russian joint stock company would be a corporation for purposes of the Act (including the foreign affiliate definition), as it is a distinct...
30 July 1996 External T.I. 9624595 - KAZACKHSTAN LIMITED LIABILITY PARTNERSHIPS
Kazackhstan Limited Liability Partnerships normally will be considered to be corporations given that they have the status of a legal entity under...
30 August 1995 External T.I. 9503045 - CORPORATE STATUS-DUTCH BV WITH UNLIMITED LIABILITY
The fact that a private company with limited liability incorporated under, and governed by the Netherlands Civil Code may not have an unlimited...
13 July 1995 External T.I. 9518095 - 6363-1 FOREIGN AFFILIATES - DEF'N OF CORPORATION
RC stated on the basis of its review of the New York Limited Liability Company Law that it was of the opinion "that a company formed under the...
25 October 1994 External T.I. 9419255 - PARTNERSHIP OR CORPORATION
A German offene Handelsgesellschaft ("OHG"), as described by the writer, would be considered a partnership for Canadian tax purposes.
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|---|---|---|
| Tax Topics - Income Tax Act - Section 96 | 21 |
25 October 1994 External T.I. 9417505 - LIMITED LIABILITY COMPANY (HAA 4093-U5-100-4)
A limited liability company organized under the applicable legislation of Florida, Wyoming, Delaware or Indiana will be considered to be a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 4 | 139 |
27 June 1994 External T.I. 9406005 - CORPORATE STATUS OF A DELAWARE LLC (4093-U5-100-4)
A limited liability company formed under Chapter 18, Subtitle II of Title 6 of the laws of Delaware will be treated as a corporation for purposes...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 250 - Subsection 250(5) | 96 | |
| Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Foreign Affiliate | 88 | |
| Tax Topics - Treaties - Income Tax Conventions - Article 4 | 67 |
27 June 1994 External T.I. 9408195 - CORPORATE STATUS OF A NOVA SCOTIA CO. (HAA 6363-1)
An unlimited liability company incorporated under the Nova Scotia Companies Act is a corporation within the meaning of s. 248 of the Act.
17 February 1994 External T.I. 9327905 F - Barbadian Limited Liability Company (Barbados Treaty)
Assuming that the proposed Barbadian Societies Restricted Liability Act is enacted in its proposed form, a foreign entity created under that...
93 C.M.TC - Q. 12
The limited liability companies for the two states that RC has reviewed (Wyoming and Florida) are considered to be corporations rather than...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Foreign Affiliate | 23 |
4 October 1990 T.I. (Tax Window, Prelim. No. 1, p. 20, ¶1022)
A foreign unlimited liability company is a "corporation" and therefore may qualify as a foreign affiliate.
IT-343R "Meaning of the Term Corporation"
Articles
Angelo Discepola, Robert Nearing, "A Reply to the CRA's Classification of Florida and Delaware LLLPs and LLPs as Corporations", 2016 Conference Report (Canadian Tax Foundation), 24:1-39
First Cdn application of two-step approach to entity classification (pp. 24:2-3)
The earliest decision to apply the two-step approach in Canadian...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 96 | 1523 | |
| Tax Topics - Statutory Interpretation - Interpretation Act - Section 35 - Subsection 35(1) - Corporation | 211 |
Michael N. Kandev, Sandra Slaats, "Recent Developments in the Foreign Affiliate Area", 2015 Annual CTF Conference paper
CRA position on partnerships under the Delaware Revised Uniform Partnership Act (p. 31:5)
Effectively, the CRA concluded [in ITTN No. 20, June 14,...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 96 | 326 | |
| Tax Topics - Income Tax Act - Section 90 - Subsection 90(9) | 284 |
Nathan Boidman, Peter Glicklich, Michael Kandev, "Canada's New Approach to U.S. LLPs and LLLPs", Tax Management International Journal, 2016, p.479
Disposition on conversion of LLP or LLP into a limited partnership (LP) or general partnership (GP) (p.480)
If CRA is correct that an LLP...
Joel Nitikman, "Is an LLP a Corporation for Canadian Tax Purposes? A Reply to the CRA", Tax Topics (Wolters Kluwer), No. 2313, July 7, 2016, p.1.
Conclusion that an LLLP or LLP is a partnership for ITA purposes given that has the following hallmarks of partnership:
(a) it has at least two...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 96 | 345 |
Nathan Boidman, "Anson and U.S. LLCs: A Canadian Perspective", Tax Notes International, August 3, 2015, p. 439.
Effect of Anson on fiscally opaque status of LLCs (p. 439)
[T]he consistent treatment of LLCs in Canada as corporations (i.e., opaque) [raises]...
Matias Milet, "Hybrid Foreign Entities, Uncertain Domestic Categories: Treaty Interpretation Beyond Familiar Boundaries", 2011 Canadian Tax Journal, Vol 59, p. 25
Wittgenstein family resemblance approach
When categorizing foreign entities so as to apply the relevant entity-based Canadian rules, it likely is...
Gwendolyn Watson, Steven Baum, "U.S. LLCs as Corporations - a New Canada Revenue Agency Position?", International Tax Planning, 2011, p. 1136
Contrary to a CRA suggestion "there does not appear to be any Canadian authority requiring that a foreign entity 'issue capital stock' in order to...
Jessica Fabbro, "What is an LLC?", CCH Tax Topics, No. 2067, 20 October 2011, p.1
Discussion of HMRC v. Anson, [2011] UKUT B21 (TCC) (reversing the finding in Swift v. HMRCI, [2010] UKFTT 88 (TC) that a US LLC was closer to a...
Jessica Fabbro, "Oh Say Can You (LL)C? A Case Comment on Boliden Westmin Ltd. v. British Columbia", CCH Tax Topics, No. 1836, 17 May 2007, p. 1: discussion of finding in that case that a Nevada LLC most closely resembled a corporation.
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|---|---|---|
| Tax Topics - Income Tax Act - Section 96 | 0 |
Marc Damo, "Characterization of Foreign Business Associations", 2005 Canadian Tax Journal, No. 2
Proposed a two-stage approach to entity classification which now is accepted by CRA (see, for example, 2010-0388621I7.)
John R. Owen, "Foreign Entity Classification and the Character of Foreign Distributions", 2005 Conference Report, c. 20
Discussion of the essential characteristics of a corporation.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Dividend | 7 |
Andersen, Wilkie, "U.S. and Third-Country Limited Liability Companies Provide Opportunities for Canadian Multinationals", Tax Management International Journal, Vol. 25, No. 5, 10 May 1996, p. 291.
Hirsch, "Real Estate Issues: Traps and Opportunities", 1995 Corporate Management Tax Conference Report, c. 9
Discussion of use of Nova Scotia unlimited liability companies for real estate investments in Canada, and of U.S. limited liability companies for...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) | 18 |
Owen, "Using a Limited Liability Company to License Intellectual Property into the United States", Taxation Law Section Newsletter, Canadian Bar Association - Ontario, Vol. 5, No. 3, May 1995, p.1.
Bernstein, "U.S. Limited Liability Corporations", Tax Profile, February 1995, Vol. 4, No. 20., pp. 201, 205.
Lanthier, "Emerging Income Tax Issues: Public Service 2,000, International Finance Companies, and U.S. Limited Liability Companies", 1993 Conference Report, pp. 3:19 - 29
Discussion of U.S. limited liability companies.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 113 - Subsection 113(1) | 7 |