Article by Chris Potter, Chris Vangou, Ken
Griffin and Susan Farina
Updates our February 24, 2012 Tax memo entitled
"Joint Ventures—CRA ends policy allowing separate
fiscal periods: How will this affect your company" to reflect
the CRA's announcement that the election to claim a
transitional reserve must be filed by September 22, 2012.
A recent Canada Revenue Agency (CRA) announcement may adversely
affect real estate companies that carry on projects or hold
investment properties through joint ventures.
Background
The 2011 federal budget proposed rules to significantly limit or
eliminate the opportunity for corporate partners in a partnership
to benefit from any tax deferrals resulting from the
partnership's ability to have a year end separate from that of
its corporate partners. The proposed rules were passed into law on
December 15, 2011. They are both complex and confusing. With the
change to the tax rules applicable to partnerships, questions arose
as to
