Partner liability: partners of an LLP are jointly and severally liable for unpaid tax unless they prove non-attribution. Where tax, penalty, interest, fee or other sums due under the Income-tax Act cannot be recovered from a limited liability partnership for any tax year, every person who was a partner of that LLP at any time during the relevant tax year is jointly and severally liable for payment of such amounts. A partner is exempt from this liability only if he proves the non-recovery cannot be attributed to any gross neglect, misfeasance or breach of duty on his part in relation to the LLP's affairs.