88 C.R. - Q.17
A corporation that is a member of a partnership may qualify for the "small manufacturer's rule".
Application of "primarily"
1.21 ... [T]he term primarily as used in paragraph 5201(a) of the Regulations signifies principally or chiefly and means more than 50%. A corporation’s activities are generally carried on by its employees. The CRA will look at the employees’ activities to determine if they are engaged principally or chiefly in manufacturing, processing, or something else. In some industries, the use of the company's assets in manufacturing or processing activities may also be considered where the use of labour does not accurately reflect the principal activities of the corporation.