Consider a case in which a foreign resource business is carried on through a limited partnership, and the partnership disposes of a foreign resource property.  In this circumstance, the rule in s. 59(1.1) of the Income Tax Act (Canada) deems a partner to realize its share of the proceeds of disposition of the property at the end of the partnership’s fiscal period.  The rule in s. 53(1)(e)(viii.1) also adds to the partner’s adjusted cost base (ACB) of its partnership interest an amount equal these deemed proceeds.  But there is a technical problem: this addition to ACB does not occur until after the partnership’s fiscal period, with the result that the partner’s “at-risk amount” in s. 96(2.2) at the end of the partnership’s fiscal period is not increased to reflect the deemed proceeds.  This, in turn, can result in a partner being unable to shelter income arising from the deemed proceeds with the partner’s share of partnership losses and resource expenditures (see s. 66.8).  The existing rule in s. 96(2.2)(b.1) solves this technical problem for the disposition of Canadian resource properties by a partnership.  There is no comparable rule for the disposition of foreign resource properties by a partnership.  The Department of Finance is aware of this technical anomaly and is considering whether a rectifying amendment is warranted.