1 November 1990 Income Tax Severed Letter

By services, 22 July, 2022
Language
English
Document number
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
657815
Extra import data
{
"field_external_guid": [
"menu:://Federal Income Tax [CCH Tax ]/Tax Window Files/Tax Window Files/Tax Window Files/1990s/1990 [NV90_433 - OC90_200.201]/NV90_380 — Conversion of General Partnership into Limited Partnership"
],
"field_proprietary_citation": [],
"field_release_date_new": "1990-11-01 07:00:00",
"field_tags": []
}
Main text
Conversion of a General Partnership
               Into a Limited Partnership

Would Revenue Canada confirm that the conversion of a general partnership to a limited partnership under Canadian jurisdiction would not result in a disposition (i.e. could be completed on a tax-free basis) where there is no change in the partners or their proportionate interests.

In general, the conversion of a general partnership to a limited partnership does not result in a disposition of the partnership interests of the general partners who become limited partners provided:

i) there has been no significant change in the rights and obligations of the partners other than potential liability; and

ii) the provincial law governing the partnership does not operate to cause a dissolution of the general partnership when there is a conversion to a limited partnership.

However, significant changes in any of the following areas upon conversion to a limited partnership may result in a disposition of the partnership interests:

i) the contributed capital accounts of any of the partners;

ii) the percentage interest in the partnership of any of the partners;

iii) the number or identity of the partners;

iv) the business of the partnership;

v) the percentage interest of each partner in the profits; or

vi) the percentage liability for losses of each partner, except for the limitation on liability of the limited partners:

CTF November, 1990 R. Albert Section 22