CRA indicates that the partnership agreement illuminates which partners control a corporation held by the partnership
In the course of a routine response, CRA noted its position that “when a partnership owns shares in a corporation … [t]he partnership agreement and the equity interest of the members must be examined to determine which member(s) of the partnership can exercise voting rights in respect of the shares of the corporation. In the case of a limited partnership … it is usually the general partner that can exercise these rights.” 2000-0038055 F and 2013-0484031E5 are similar.
This effectively elevates the partnership agreement to a similar status to articles and unanimous shareholder agreements in determining control and relatedness.
Neal Armstrong. Summary of 3 April 2019 Internal T.I. 2018-0787561I7 under s. 251(2)(c)(i).