27 October 2020 CTF Roundtable Q. 9, 2020-0866671C6 - entity classification of UK LLP -- summary under Section 96

CRA indicated that, under its two-step approach, a UK LLP is a corporation rather than a partnership given that:

  • A UK LLP has a legal existence separate from its members.
  • A UK LLP, and not its members, carry on the business.
  • A UK LLP, and not its members, acquires and owns property in its own name for use in its business, and is responsible for any debts or obligations incurred as a result of carrying on its business.
  • The capital of a UK LLP serves the same function as the share capital of a corporation.
Topics and taglines
Topic
Income Tax Act - s. 96
Tagline
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
604979
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
604980
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