While challenging to the practitioner, the uniqueness of partnerships gives rise to unique tax planning opportunities.  Perhaps the most important of the planning advantages offered by partnerships is the elimination of entity level taxation, which permits the flow through of income and losses to the partners untaxed at the partnership level.  Another is the potential for corporate partners in a partnership to enjoy increased tax deferral, and in some cases an increased claim to the small business deduction.

Also important is the ability in a partnership to allocate income selectively, and to easily change that allocation when business circumstances warrant it.  Partnerships also present opportunities to carry out tax deferred reorganizations with what are sometimes particularly advantageous terms. 

This course will introduce you to each of these planning topics, as well as to some of the anti-avoidance provisions to which these planning opportunities give rise, particularly the at-risk rules which limit deductions for limited partnerships and tax shelters to the at-risk amounts invested.

The course is comprised of ten self-study modules and is based on the Income Tax Act as it stood at February 4, 2011.  Also included are the measures affecting partnerships announced in the March 22, 2011 federal budget and reintroduced in the June 6, 2011 budget. Any pending legislative amendments, pronouncements, and proposals announced up to then are incorporated into these materials. There are also two quizzes to test your understanding of the concepts of the course.

While this course is self-contained, you are expected to have a current Income Tax Act (ITA), as some of the ITA references included in these materials are paraphrased or merely cited, and you will want to refer to the actual provisions to build your comprehension.

Module 1 Law of partnerships

Module 2 Taxation of partnerships

Module 3 Partnership interests

Module 4 Formation of partnerships

Module 5 Withdrawal or retirement

Quiz 1

Module 6 Dissolution of a partnership

Module 7 Incorporation of a partnership

Module 8 At-risk rules

Module 9 Sales taxes

Module 10 Using partnerships in tax planning

Quiz 2