CRA treats a partnership interest as a single property - but shareholdings are different!

CRA may view the interest of a taxpayer in a partnership as a single property.  For example, the taxpayer may not accomplish anything by purporting to hold both preferred and participating partnership interests with supposedly separate adjusted cost bases.  Consistently with this view, CRA considers that the s. 70(6.2) election, to deem  a "property" of a deceased taxpayer passing to a spouse to be disposed of for its fair market value, cannot be made with respect to a portion of the taxpayer's partnership interest (including, presumably, units of a unitized partnership).

However, each share of a corporation is viewed as a separate property, so that the election can be made with respect to a portion of the deceased taxpayer's shareholdings (except in the unusual situation where he or she held only one share).

Neal Armstrong.  Summary of 12 June 2012 STEP CRA Roundtable, Q. 9 2012-0442921C6 under s. 70(6.2).