S. 100 rules extend to negative ACB amounts

Where a general partner interest is sold to a non-resident or tax exempt, any negative ACB amount is included in the amount which is 100% rather than 50% taxable (except to the extent that the it is attributable to non-depreciable property capital property). It is unclear whether this is an intended result.

Neal Armstrong. Summary of Paul Cormack and Janette Pantry, "Negative Partnership Interest ACB," Canadian Tax Highlights, Vol. 24, No. 8, August 2016, p. 2 under s. 100.