17 May 2012 IFA Roundtable, 2012-0444081C6 - 2012 IFA Seminar - Question 4 -- summary under Subsection 116(1)

Respecting a disposition of taxable Canadian property by a widely-held partnership, or by a multi-tier partnerships where it is not possible to ascertain all the indirect partners, CRA stated:

it is current CRA policy to accept one notification of disposition filed on behalf of all partners on the condition that sufficient information about each individual partner is provided. Therefore, along with the one notice, the CRA requires a complete listing of the non-resident partners who are disposing of the property, including their Canadian and foreign addresses, tax identification numbers, percentage of ownership, and their respective portion of the payments or security. A partnership cannot file one income tax return on behalf of all the partners because the legislation does not provide for this filing method.

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