The two types of PLOI elections operate differently for partnerships

A "PLOI" election can be made under s. 15(2.11) to avoid an income inclusion under s. 15(2) for a loan made made by a partnership between a CRIC (controlled by a non-resident corporation) and other Canadian corporates to a connected non-resident corporation.  The election must be made by the filing due date for "the" CRIC.  CRA considers that where more than one foreign controlled CRIC is a partner, this filing due date references the latest of the relevant filing-due dates of those CRICs.

On the other hand, such a partnership would be a look-through for purposes of the PLOI election which is available under the foreign-affiliate dumping rules for a loan made by the partnership to a subject corporation, so that the PLOI election would only be made by the subject corporation and the CRIC based on the CRIC’s proportionate share of the loan.

Neal Armstrong. Summaries of 18 June 2014 T.I. 2014-0534541I7 under s. 15(2.11) and s. 212.3(11).