CRA clarifies how its policy, to allow one member of a related group to file their T1134s, applies to a partnership

CRA’s published policy is to allow reporting entities that are members of the same group of related reporting entities to file a single T1134 report for all foreign affiliates for which they would otherwise have to file a T1134, provided that they belong to the same “related group” as defined in s. 251(4), have the same year-end, and report in Canadian currency (or the same functional currency).

CRA elaborated that if a partnership is a reporting entity (i.e., it has Canadian resident partners who are not exempt from Part I tax and who hold at least a 10% interest in the partnership's income or loss for the period), then this administrative relief will be extended to the partnership if at least one of its partners (or, if one of the partners is also a partnership, a partner of that partnership, and so on) is related to each of the other reporting entities forming a “related group” in respect of the same foreign affiliates.

Neal Armstrong. Summary of 2 December 2025 CTF Roundtable, Q.4 under s. 233.4(4).