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Canada: Temporary relief for partnerships subject to CRS obligations

Partnerships treated as Canadian residents for CRS purposes only if effective management in Canada

april 16, 2026

The Canada Revenue Agency (CRA) on April 10, 2026, announced a reversal from its updated common reporting standard (CRS) guidance issued in December 2025 which broadened the circumstances under which a partnership may be considered a Canadian resident for CRS purposes.

The CRA announced that a partnership will be considered a Canadian resident for CRS purposes only if the place of effective management of the partnership's business is situated in Canada. The CRA stated that the CRS guidance for partnerships is currently being reviewed and may be revised at a later date. The remainder of the CRA’s revised guidance announced in 2025 remains in place.

Read an April 2026 report prepared by the KPMG member firm in Canada

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