On September 8, 2017, the Department of Finance
("Finance") released a series of draft legislative
changes to the Excise Tax Act (Canada) (the
"ETA"). Of particular note is legislation that will have
broad ranging impact on limited partnerships that are engaged in
investment activities including investment in other
partnerships.
Do these rules apply to your limited partnership?
These new rules apply to "investment limited
partnerships." This newly defined term includes limited
partnerships ("LP"), the primary purpose of which is to
invest funds in property consisting primarily of financial
instruments (which includes equity securities, debt securities,
insurance policies, interests in partnerships, trusts, or any
options / guarantees in respect of the foregoing), and that meet
one of the following two conditions (i.e., (a) or (b)):