The CRA has now announced that a partnership will be considered a Canadian resident for CRS purposes where the place of effective management of the partnership's business is situated in Canada. This new reprieve, which was announced on April 10, 2026, reverses course on an earlier position announced on December 19, 2025 in which the CRA broadly expanded the circumstances under which a partnership may be considered a Canadian resident for CRS purposes. The CRA states that the CRS guidance for partnerships is currently being reviewed and may be revised at a later date. Note that the remainder of the CRA’s revised guidance announced in 2025 remains in place.
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