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In Print: Selected Issues Regarding Partnerships and Section 261
The expansion of section 261 to include partnerships was a welcome change for many taxpayers hoping to take advantage of the currency election rules. However, any taxpayers hoping to utilize these amendments should be aware that the method chosen by the Department of Finance to implement the expanded scope of these rules raises many issues. A corporation that has an elected tax reporting currency is likely to find that acquiring an interest in a partnership can quickly result in a number of complications. It will be interesting to see how CRA interprets section 261 as it relates to partnerships, and if the ministry continues to make adjustments to section 261 to address the types of concerns raised in this article.
