Where a partnership has realized only $150,000 in capital gains from the disposition of capital property eligible for the capital gains deduction and $200,000 in capital losses, can 50% of each of these amounts be allocated separately to a 50% partner who personally realized $200,000 in capital gains that were not eligible for the CGD so that the net result to him would be a capital gain of $150,000 eligible for the CGD? In responding affirmatively, CRA stated:
For the purposes of section 3, the amount of a partnership's income from each source is the taxpayer's income from that source by virtue of paragraph 96(1)(f).
Thus, the amount of the taxable capital gain or allowable capital loss resulting from the disposition of each property by the partnership would, in its turn, constitute the taxable capital gain or allowable capital loss of the member for the purposes of paragraph 3(b), and would be taken into account in computing the deductible amount in computing taxable income by virtue of section 110.6.