Subsection 85(3) requires that a partnership be wound-up within 60 days after the disposition of property to a corporation under subsection 85(2). The CRA accepts that a partnership has been wound up even if the legal title to real property remains in the partnership but the beneficial ownership has been transferred. See Neal Armstrong’s summary of technical interpretation 2014-0559731E5 dated January 14, 2015. All the more reason to have a detailed winding-up agreement that includes a provision providing for the transfer of the beneficial interest with the transferor holding legal title only as a nominee.
