17 January 2017 Internal T.I. 2016-0647161I7 - Capital gains of a partnership -- summary under Paragraph 96(8)(c)

Although where a member of a non-resident partnership becomes a Canadian resident in a year, s. 96(8) prevents the recognition for ITA purposes of losses realized by the partnership from dispositions in the year prior to the immigration, there is no symmetrical application for capital gains realized in the year of a property (e.g., U.S. real estate) prior to the immigration, so that the new resident must include his or her share of that gain in income for that year.