| 19(1) | File No. 5-8633 |
| R.B. Day | |
| (613) 957-2136 |
November 2, 1989
19(1)
We are writing in reply to your letter of August 30, 1989, wherein you requested our views as to whether or not a partnership would be considered a person for the purposes of section 54.2 of the Income Tax Act.
Our Comments
Paragraph 1 of IT-90 states, in part, that "a partnership is not a person nor is it deemed to be within the meaning of the Act, notwithstanding that section 96 provides that the income of a member of a partnership is computed as if the partnership were a separate person resident in Canada."
In view of the above, it is our opinion that a partnership would not be considered a person for purposes of section 54.2.
Yours truly,
for DirectorBusiness and General DivisionSpecialty Rulings DirectorateLegislative and IntergovernmentalAffairs Branch