5.0 Other Jurisdictions' Initiatives
It is our understanding other jurisdictions have examined or have enacted
provisions that deal with LLPs. We have not embarked on a comparison of these
We note Great Britain enacted LLP legislation in 2000. Their legislation treats
the LLP as a separate legal entity apart from its partners. This is a significant
difference to Canadian and United States initiatives that continue the concept the
LLP is only a variation of a partnership and thus, not a separate legal entity. Due
to this, Great Britain’s legislation must address policy issues that arise due to the
approach – termination of the old partnership, transfer of assets to the LLP,
accounting and taxation matters, etc.
Sections 6 and 7 of the Report discuss LLP policy issues in the context of the Canadian and United States legislative environment.
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