Article 1

Administrative Policy

17 June 2004 IFA Roundtable Q. 2, 2004-0072381C6 - Flow-through treaty benefits partnership

CRA is revisiting the issue whether a partner resident in a treaty country should receive the benefits of a tax treaty between Canada and that treaty country where the partner is a member of a partnership formed in Canada which is transparent for Canadian tax purposes but is considered to be a foreign corporation for purposes of the treaty country's tax system, so that the partners are not actually taxable on the partnership income in the treaty country.