In 2014-0529311E5, the CRA considered a hypothetical case where a partner was selling its partnership interest and wished to cause a fiscal year end for the partnership before the sale (under s. 249.1(7)). This change would allow the departing partner access to the partnership’s losses realized before the sale. Without this change, the partnership’s losses could be reduced by the partnership’s profits realized after the sale and before the end of the partnership’s fiscal period. The rule in s. 96(1.01) would be of no assistance to the departing partner, as the losses might be eliminated by the end of the partnership’s fiscal period. The CRA said it would deny the request to change the partnership’s fiscal period on these facts because a change in fiscal year is allowed only where the change is prompted solely by sound business reasons. Personal convenience of a taxpayer or some tax benefit is not considered a sound business reason (in this context). Furthermore, in this case the proposed change would result in misaligning the fiscal periods of the multi-tier partnership contrary to the underlying rationale of s. 249.1(1)(c).