16 December 2005 External T.I. 2005-0150411E5 F - Roll-over Provisions and Partnership -- summary under Paragraph 96(1)(a)

CRA indicated that, given that a partnership’s income was computed as if it were a separate resident person, it was a “taxpayer” for s. 51(1), 85.1(1) or 86(1) rollover purposes, even if it had non-resident partners.