30 September 1992 T.I. (Tax Window, No. 24, p. 18, ¶2180) -- summary under Paragraph 96(2.4)(d)

The word "arrangement" is open to very broad interpretation ranging from formal contracts to verbal understandings. S.96(2.4)(d) can apply where a partner disposes of his interest in a general partnership to another person for the sole purpose of limiting its liability, and one of the main reasons for the agreement or other arrangement for the disposition was avoidance of the application of s. 96(2.4)(a), (b) or (c).