Revenue Canada Revenu Canada Taxation Impôt
Head Office Bureau principal
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APR AVR 21 1989
Dear Sirs:
Re: Section 86 of the Income Tax Act (Canada) (the "Act") ------------------------------------
This is in reply to your letter of April 6, 1989 wherein you requested our opinion as to whether a partnership is considered as a "taxpayer" for purposes of section 86 of the Act.
Notwithstanding that a partnership is not a person, it is the view of the Department that a partnership qualifies as a "taxpayer" for purposes of section 86 of the Act because of the operation of the general rule in paragraph 96(1)(a) of the Act.
The foregoing comment is not a ruling and in accordance with the guidelines explained in Information Circular 70-6R dated December 18, 1978 is not binding on the Department.
Yours truly,
for Director Reorganizations and Non-Resident Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch