Under s. 98(3), a partnership may be dissolved on a tax-deferred basis generally if the partners receive an undivided interest in the partnership’s property and an election is timely filed with the Canada Revenue Agency (CRA). In 2014-0540611E5, the CRA said that an election filed under s. 98(3) (Form T2060) must refer to all the partnership’s property. In the CRA’s view, if an election does not refer to all the partnership property, the entire election is invalid. Furthermore, the CRA said that the Minister has no discretion to amend an (incomplete) election, because s. 98(3) is not among the provisions referred to in s. 600 of the Regulations.