Is an amount included in a corporation’s income under s. 34.2(2) added by virtue of s. 53(1)(e) to the adjusted cost base of its partnership interest? CRA responded:
[T]he amount included under subsection 34.2(2)… will not be included in the corporation's share of the partnership's income from any source. Therefore, for the purposes of subparagraph 53(1)(e)(i), there would be no addition to the ACB to the corporation of the partnership interest in an amount otherwise included in the income of the corporation under subsection 34.2(2).
Furthermore, there is no other provision in paragraph 53(1)(e) for adding, to the ACB of the partnership interest, the amount that would be included in computing the corporation's income under subsection 34.2(2).