CRA currently is inclining to classify Delaware and Florida LLPs and LLLPs as corporations

CRA is "heavily leaning" towards characterizing Florida limited liability partnerships (LLPs) and Florida limited liability limited partnerships (LLLPs) as corporations, and is a few weeks away from reaching a definitive conclusion on this point.  Its preliminary view is that the equivalents under Delaware law also are corporations.

Neal Armstrong. Summary of 24 November 2015 CTF Annual Roundtable, Q. 7(b) under 2015 CTF Roundtable.