Jessica Fabbro, "Dispositions of Partnership Interests – Navigating the Amendments to Section 100 of the Income Tax Act", CCH Tax Topics, No. 2162, August 15, 2013, p. 1

Summary Under
Tax Topics - Income Tax Act - Section 100 - Subsection 100(1.1)
Purpose of s. 100(1.1)(d) (p.2)

…[P]aragraph 100(1.1)(d) does not include a trust merely because it has a non-resident beneficiary. While the...

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Summary Under
Tax Topics - Income Tax Act - Section 100 - Subsection 100(1.3)
Reason for rule (p. 3)

Subsection 100(1.3) applies where the purchaser of the partnership interest is a non-resident and partnership property is...

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