27 March 2018 Internal T.I. 2015-0592551I7 - Excluded property status of partnership interest -- summary under Subsection 98(2)

On the winding-up of an Icelandic partnership, it disposed of all its loans for cash, distributed most of its cash to its two partners, made a final cash distribution and some time later it was formally dissolved under Icelandic law. The Directorate indicated that it was unnecessary for it to pass on whether the partners disposed of their partnership interests on the final distribution date under s. 98(2), or whether the disposition occurred on the formal dissolution date.