15 February 2007 External T.I. 2006-0214151E5 - Disposition of Partnership Interest -- summary under Disposition

With respect to an inquiry as to whether a capital loss could be claimed on a partnership interest in circumstances in which unsuccessful attempts had been made to have the unit holders vote on a formal dissolution of the partnership, CRA stated that "in our view, the dissolution of a partnership could trigger the disposition of the partnership interest in a partnership for nil proceeds of disposition".