Marshall Haughey, "Tiered Partnerships: Successor Rules", Canadian Tax Highlights, Vol. 22, No. 2, February 2014, p. 13.

Summary Under
Tax Topics - Income Tax Act - Section 66.7 - Subsection 66.7(10) - Paragraph 66.7(10)(j)
Creation of 2-tier partnership structure before v. after acquisition of control (p. 14)

Interestingly, if the tiered partnership structure in...

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Summary Under
Tax Topics - Income Tax Act - Section 66.7 - Subsection 66.7(16)
Transfer of successored property to a partnership (pp. 14-5)

It is also interesting that the Crown did not argue subsection 66.7(16) [in Devon, The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.