CRA indicates that an LLC resulting from a conversion from a USLP has high inside and outside basis
CRA had previously commented that the conversion of particular USLPs into LLCs gave rise to FMV dispositions at the member and USLP level. CRA has now stated its “general view” (subject to a caveat about ruling applications being better) that the starting outside and inside basis for the new LLC also would be such FMV. CRA also adverted to its recent position that US LLPs and LLLPs generally are corporations – but it was beyond the scope of the question to comment on conversions going the other way, e.g., converting an LLP (viewed as a corporation) into an LP.
Neal Armstrong. Summary of 21 November 2017 CTF Annual Conference CRA Roundtable, Q.15 (Official Response) under s. 95(2)(f).