CRA treats a partner-to-partnership loan as a debt owing to the partner by each other member

The s. 96 rule that a partnership is a separate person for income-computation purposes does not apply in determining whether a debt owing to a Canadian resident by a foreign partnership is "indebtedness owing by a non-resident person" for purposes of the requirement in s. 233.1 to report such indebtedness and other "specified foreign property."  However, if the obligations of the partners for partnership debt are joint and several, each non-resident partner is considered to owe the full amount of the debt to the Canadian resident, so that the debt will be specified foreign property on that basis.

This conclusion is not affected if the Canadian resident also is a partner, so that in that respect the loan is owed by it to itself.

Neal Armstrong.  Summary of 24 February 2014 Memo 2013-0484461I7 under s. 233.3(1) – specified foreign property.