CRA requires the dissolution of a non-existent limited partnership in order to trigger a disposition of the LP units

CRA accepted the questionable assertion of a correspondent that a limited partnership which had ceased all activity and no longer had any assets (and, therefore, no longer represents a business carried on in common with a view to profit) "has not legally ceased to exist." (If it’s still registered, it must still exist, right?) CRA then went on to conclude that as the s. 50(1) rule did not extend to LP units, it would be necessary to "dissolve" the partnership in order to trigger their disposition.

Neal Armstrong.  Summary of 3 January 2014 T.I. 2013-0482081E5 under s. 50(1).