CRA ruling appears to accept that partnership loss or income can be allocated disproportionately to the capital accounts

In order to be allocated a portion of the losses of a partially-owned subsidiary, the subsidiary will roll its business into a newly-formed subsidiary LP for Class A units, and the majority shareholder then will fund the LP's need for additional capital by subscribing directly for Class B units with the same per-unit income entitlement.  Although the ruling letter is ambiguously drafted on the point, CRA appears to have accepted that loss (or income) will be allocated between the Class A and B unitholders in proportion to their respective number of units, even though capital distributions (i.e., in excess of income) can be made disproportionately on the Class A and B units.

Neal Armstrong.  Summary of 2012 Ruling 2011-0421261R3 under s. 103(1).