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FEDERAL INCOME TAX - Partnerships - Limited partnership - Administration and enforcement

Friday, December 15, 2017 @ 10:35 AM  

Appeal by nine corporate partners in a limited partnership for the purpose of challenging the enforceability of a settlement agreement with Canada Revenue. The appellants were involved in film production conducted through four master limited partnerships (MLPs) associated through common promoters. An audit of the MLPs raised concerns regarding certain deductions claimed in connection with expenses. In 2004, a settlement agreement in respect of the tax treatment of various expenses was signed by Canada Revenue and a signatory who represented the four MLPs and related limited...