A limited partner has both losses from other sources and losses and limited partnership losses from the limited partnership. Based on the "non-capital loss" ("NCL") definition in s. 111(8), its NCL would not be increased by the amount deducted by virtue of s. 111(1)(e). Is this correct? CRA responded:
We agree with you that the amount of a limited partnership loss is not considered for purposes of computing the taxpayer's NCL. In fact, the amount of the NCL, as defined in subsection 111(8), is not increased by the amount that would otherwise be deductible under paragraph 111(1)(e) for a given taxation year.
Based on our understanding of tax policy, this result appears consistent with the one underlying the restrictions on the deductibility of partnership losses sustained by a taxpayer in a partnership.