Principal Issues: Would paragraph 249.1(1)(c) of the Act apply to a partnership if its wholly-owned corporation becomes a member of another partnership?
Position: No. A partnership's indirect investment in another partnership through its wholly-owned corporation would not, in and of itself, cause the partnership to be within the ambit of paragraph 249.1(1)(c).
Reasons: Paragraph 249.1(1)(c) is concerned with tiered partnership structures and contemplates a membership interest in a partnership that is held directly, or indirectly through one or more partnerships, by a partnership.