CRA noted that the 2016 Budget proposes to extend the specified partnership income rules to partnership structures in which a Canadian-controlled private corporation (“CCPC”) provides (directly or indirectly, in any manner whatever) services or property to a partnership during a taxation year of the CCPC where, at any time during the year, the CCPC or a shareholder of the CCPC is a member of the partnership or does not deal at arm’s length with a member of the partnership (and that the Budget rules extend to comparable private corporation structures). CRA then stated:
With respect to any advance income tax rulings involving such partnership reorganization structures…any advance income tax rulings issued by the CRA will cease to bind the CRA on the coming into force of the proposed legislation.