A year-end income allocation by a non-resident partnership to an immigrant included offshore capital gains realized pre-immigration
Where a member of a non-resident partnership becomes a Canadian resident in a year, s. 96(8) prevents the recognition for ITA purposes of losses realized by the partnership from dispositions occurring in that year but prior to the immigration. There is no symmetrical application for capital gains realized from a disposition in the year of a property (e.g., U.S. real estate) occurring prior to the immigration, so that the new resident must include his or her share of that gain in computing income for that year.
Neal Armstrong. Summary of 17 January 2017 Internal T.I. 2016-0647161I7 under s. 114.