15 May 2024 IFA Roundtable Q. 4, 2024-1007571C6 - Late-filed PLOI election -- summary under Subsection 15(2.12)

CRA indicated that it has revised its procedures for the late-filing of a PLOI election. Although this can still be accomplished by the corporation resident in Canada (CRIC) filing an amended Schedule I, the CRIC can instead use recently published CRA forms (Forms T1521 and T2311 for filings under s. 15(2.11) and s. 212.3(11), respectively) to provide the relevant information.

Regarding loan indebtedness owing to a qualified Canadian partnership, currently the instructions contained in Part 3 of Form T1521 indicates that filing an amended partnership information return is not required. These instructions will be revised to clarify that, in order to process the adjustment in respect of the qualified Canadian partnership and corporate partners, the taxpayer should submit an amended partnership information return (or returns, depending on the partnership structure) as well as amended Schedule 1 or any other applicable schedules of corporate partners in order for the elections to be processed effectively.

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