After emigrating from Canada, an individual transferred his interest in a real estate partnership on a s. 85(1) rollover basis to a corporation of which he was the sole shareholder. In confirming that the partnership interest could be eligible property, CRA reiterated an earlier position that:
An interest in a partnership is not considered to be an interest in its underlying assets for purposes of section 85. An interest in a partnership could be held by its owner as capital property or inventory, depending on the circumstances. An interest in a partnership with assets that include an inventory of real property would be eligible for a subsection 85(1) transfer.