CRA applies the proposition (regarding a s. 90(3) PUC distribution election) that a partnership cannot be a related person

A limited partnership (LP) - whose 90% general partner is FA1 (held by Canco1) and whose 10% limited partner is FA2 (held by Canco2, which is related to Canco1) – receives a paid-up capital distribution from its wholly-owned subsidiary (FA3). CRA confirmed that an s. 90(3) election respecting the distribution could be made by LP alone (or, to be more precise, by FA1 in its capacity of the general partner of LP) given that there is no “connected person or partnership” in respect of LP within the meaning of s. 90(4).

Neal Armstrong. Summary of 17 May 2022 IFA Roundtable, Q.14 under s. 90(4).