2022-0941241R3 concerned inter alia (i) two general partnerships: Partnership C between ParentCo and its wholly-owned subsidiary, SubCo; and Partnership D, between ParentCo, Partnership C, and NewCo2 (held by ParentCo and SubCo); (2) the successive windings-up by operation of law of Partnerships C and D as a consequence of the winding-up of SubCo, then NewCo2. CRA ruled inter alia as to the application of s. 98(5) to the two wind-ups.
Now, in 2024-1008661R3, CRA ruled that, provided that (the 364-day rule in) Reg. 1100(2.2)(f) was satisfied (or as per Reg. 1100(2.2)(g), the Reg. 1100(2.2) exception applied to the transferor), the half-year rule in Reg. 1100(2) did not apply by virtue of Reg. 1100(2.2) to the depreciable property acquired by ParentCo on the two partnership wind-ups.