Section 98.1

Subsection 98.1(1) - Residual interest in partnership

Administrative Policy

13 September 1994 T.I. 5-941759 -

A person who retires and disposes of a partnership interest at any time during a particular fiscal period of a partnership will be considered to have a residual interest in the partnership where that person is allocated a share of the partnership income or loss (accruing during the time the person was a member) at the end of that particular fiscal period of the partnership. [To same effect: 11 August 1994 T.I. 5-941590 (C.T.O. "Residual Interest in a Partnership")]

IT-278R "Death of a Partner or a Retired Partner"

IT-242 "Retired Partners" under "Residual Interest"

Subsection 98.1(2) - Continuation of original partnership

Administrative Policy

14 October 1997 T.I. 5-972435 -

Re-application of s. 98.1(2) where a number of U.S. limited partnerships merged to form a single limited partnership.