CRA acknowledges that a corporation is a blocker for recognizing a multi-tier partnership

Subject to exceptions, s. 249.1(1)(c) provides that a partnership must have a calendar year end if it "is a member of another partnership." CRA recognizes that this stipulation is not triggered if a partnership corporate subsidiary is a member of another partnership.

And, no, this is not a concern re s. 88(1)(c.2)(iii), which uses the much broader concept of a "direct or indirect interest in…shares" of another corporation.

Neal Armstrong. Summaries of 18 August 2014 T.I. 2014-0528001E5 under s. 249.1(1)(c) and s. 249.1(4).