Kabir Jamal quoted in "Canada to Tax Florida, Delaware Partnerships as Corporations", the Daily Tax Report
Excerpt from "Canada to Tax Florida, Delaware Partnerships as Corporations", by Peter Menyasz:
Kabir Jamal, an associate in the Toronto office of Goodmans LLP, agreed the decision wasn't surprising considering the tax agency's indication in November 2015 that it was “heavily leaning” toward that approach, and that it raises “thorny” issues similar to those for U.S. limited liability corporations.
In addition to lack of clarity on benefits under the bilateral tax treaty, it raises questions about the eligibility of such entities for Canadian foreign tax credits for taxes paid outside Canada and their tax treaty residency for Canadian tax purposes, Jamal told Bloomberg BNA in an e-mail.
“It remains to be seen how the Canada Revenue Agency will respond to these issues,” he said.