Corporate Partnership Deferral Elimination 

The 2011 Canadian federal budget included proposals to limit the deferral opportunities for corporations (other than professional corporations) with significant interests in partnerships that have a fiscal period different from the corporation’s taxation year.

 

This change could have broad implications for corporations that are members of partnerships and may result in significant incremental partnership income in the first taxation year that ends after March 22, 2011 if a transitional reserve is not available.

Do the Proposed Partnership Tax Deferral Changes Affect You?

 

This proposal would affect partnership interests where a corporate partner, together with affiliated and related parties, is entitled to more than 10 percent of the partnership’s income (or assets in the case of a wind-up) at the end of the last fiscal period of the partnership that ended in the taxation year.

 

The proposed measure requires the corporation to include the income of the partnership for the taxation year that ends in the corporation’s taxation year, and to accrue partnership income for a stub period (Stub-Period Accrual) of the partnership’s subsequent taxation year, which begins in that taxation year and ends in the following taxation year.

 

Do the Proposed Partnership Tax Defferal Changes Affect You?

 

This special issue of TaxNewsFlash-Canada outlines how the result of the Corporate Partnership Deferral Elimination may affect your business.

 

KPMG is Here to Help: Our Tax Professionals are well versed in the corporate partnership tax deferral changes and can provide you with advice on these matters. Please contact any member of our team listed below:

 

Greater Toronto Area
Penelope Woolford Lorne Shillinger Antony Schiefer

Penelope Woolford

Partner in charge of International Corporate Tax (GTA)

416-777-8906

Contact by e-mail

Lorne Shillinger

Partner, Tax

416-777-8692

Contact by e-mail

Antony Schiefer

Partner, Tax

416-777-8361

Contact by e-mail

Jeff Oldewening

Jeff Oldewening

Associate, Taxation 

416-861-0505 

Contact by e-mail

 

Greater Vancouver Area
Mark Meredith Roque H. Hsieh Tony L. Tse

Mark Meredith

Partner, International Tax

604-691-3478

Contact by e-mail

Roque H. Hsieh

Partner, Tax

604-691-3243

Contact by e-mail

Tony L. Tse

Associate Partner, Tax

604-691-3078

Contact by e-mail

 

Montreal
Hugues Lachance    

Hugues Lachance

Associate partner

514-840-2542

Contact by e-mail

   

 

Calgary
Torran A. Jolly Jason Boland  

Torran A. Jolly

Partner, Tax

403-691-8127

Contact by e-mail

Jason Boland

Partner, Tax

403-691-8112

Contact by e-mail

 

 

Regions West
Glen Demke, CA-CBC, TEP Allan Thordarson  

Glen Demke, CA-CBC, TEP

Partner, Tax Enterprise Regions West

780 429 7395

Contact by e-mail

Allan Thordarson

Partner

204-957-2277

Contact by e-mail

 

 

Regions East
Tom H. Wightman David S. Downie  

Tom H. Wightman

Partner, Tax

613-541-7315

Contact by e-mail

David S. Downie

Partner, Tax

519-747-8867

Contact by e-mail

 

 

Penelope Woolford

Penelope Woolford

Partner in charge of International Corporate Tax (GTA)

416-777-8906

Lorne Shillinger

Lorne Shillinger

Partner, Tax

416-777-8692

Antony Schiefer

Antony Schiefer

Partner, Tax

416-777-8361

Greater Vancouver Area

Mark Meredith

Mark Meredith

Partner, International Tax

604-691-3478

Roque H. Hsieh

Roque H. Hsieh

Partner, Tax

604-691-3243

Tony L. Tse

Tony L. Tse

Partner, Tax

604-691-3078

Montreal

Hugues Lachance

Hugues Lachance

Partner, Tax, KPMG Canada

514-840-2542

Calgery

Torran A. Jolly

Torran A. Jolly

Partner, Tax

403-691-8127

Regions West

Glen Demke

Glen Demke

Partner, Tax Enterprise Regions West

780-429-7395

Allan Thordarson

Allan Thordarson

Partner

204-957-2277

Regions East

Tom H. Wightman

Tom H. Wightman

Partner, Tax

613-541-7315

David S. Downie

David S. Downie

Partner, Tax

519-747-8867