CRA is non-commital on alternative technique for partnership merger

Interpretation Bulletin IT-471R contemplates that two partnerships can merge by winding-up under s. 98(5) with the former partners then contributing the former partnership property to a single partnership utilizing s. 97(2).  CRA has indicated that it is not "impossible" that two partnerships also could be merged on a rollover basis by the first partnership contributing its property to the second partnership utilizing s. 97(2), with the first partnership then being wound up under s. 98(3).

Neal Armstrong.  Summary of 4 July 2012 T.I. 2011-0429601E5 F under s. 98(5).