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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 initiatives.

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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