In clarifying that it had not recently changed its view that a French société en nom collectif ("SNC") was a partnership rather than a corporation for ITA purposes, CRA stated:
CRA … considers a French SNC that has its place of effective management in France for French tax purposes, to be a partnership for the purposes of the Act regardless of whether or not it has made an irrevocable election to be taxed as a corporation under French tax law. It was not our intention to indicate in our document 2003-0051301E5 that this position was under review or had been changed.