US LLLPs are partnerships

Notwithstanding that CRA declined (in 2014-0523041C6) to conclude on the point outside the context of a ruling request, a Delaware limited liability limited partnership should qualify as a partnership for Canadian taxation purposes given that it is essentially the same thing as a "regular" Delaware LP except for some somewhat enhanced limited liability protection.

Neal Armstrong. Summary of Kenneth Snider, "US Limited Liability Partnerships – DRUPA Revisited," International Tax (Wolters Kluwer CCH), Number 77, August 2014, p. 4 under s. 96.