CRA finds that s. 98(5) is not available where a landlord partnership is wound-up into the tenant partner
2 April 2012 - 9:23am
CRA indicated in a French technical interpretation that the s. 98(5) rollover was not available where the wound-up partnership had been renting its sole property (a retirement residence) to the partner into which it was wound-up (because the rental activity ceased on the merger of tenant and landlord). This is another illustration that the s. 98(5) is available in a narrower set of circumstances than under s. 98(3).
Neal Armstrong. Summary under ITA s. 98(5).