The sole limited partner (LPco) transfers it interest in an LP under s. 85(1) to GP, thereby triggering the dissolution of the LP. There was a representation that the partnership ceased to exist, and all its property became property of GPco, “upon” the partnership interest transfer.
CRA ruled that, by virtue of s. 99(1) deeming the LP fiscal period to have ended two instants of time before the termination of the LP, the ACB of the transferred partnership interest reflected a proportionate share of LP’s income for the year ending with the termination of LP– and also ruled re the application s. 98(5).