In the Technical News No. 5, dated July 28, 1995, we mention that in computing the adjusted cost base (ACB) of a partner's partnership interest at a particular time, only the partnership's income or loss for fiscal periods ending before that time will be taken into account. ..
… In circumstances where there is a possibility of double taxation, we are prepared, in the context of a ruling request, to apply the law in a manner such that a taxpayer is not taxed twice on the same amount. For example, if a partner dies or leaves the partnership, we may consider certain adjustments in situations where double taxation arises.
The Department of Finance agrees with our position and is currently reviewing the relevant provisions of the law to establish if legislative amendments are necessary.