I-3, r. 1 - Regulation respecting the Taxation Act

Section 851.22.11r9 Disposition versions

2012-09-01

851.22.11R9. If section 633 of the Act deems a partnership, referred to in this section as the “new partnership”, to be a continuation of another partnership, referred to in this section as the “predecessor partnership”, the following rules apply in respect of the residual portion of a gain or loss of the predecessor partnership from the disposition of a specified debt obligation to which section 851.22.11 of the Act applies:

(a)  the amount allocated to the taxation year of the predecessor partnership in which its property was transferred to the new partnership, in respect of the residual portion of the gain or loss, is determined on the assumption that the taxation year ended when the property was transferred to the new partnership;

(b)  no amount is allocated, in respect of the residual portion of the gain or loss, to any taxation year of the predecessor partnership after its taxation year in which its property was transferred to the new partnership; and

(c)  the amount allocated to the taxation year of the new partnership in which the predecessor partnership’s property was transferred to it, in respect of the residual portion of gain or loss, is determined on the assumption that the taxation year began when the property was transferred to it.

O.C. 390-2012, s. 64.