In 2013-0484031E5, the CRA confirmed that a partnership is not a “person” that can acquire legal control of a corporation. Rather, the CRA will look to which partner (or partners) can legally exercise voting rights in respect of the corporation’s shares under the partnership agreement. In the context of a limited partnership, this is typically the general partner. The CRA applied this reasoning in the context of s. 256(7)(a)(i)(B), which can operate to ignore an acquisition of legal control where the “person” who acquires that control is related to the corporation. Although not mentioned by the CRA, further considerations should include (i) who has legal control of the limited partner (s. 256(6.1)), and (ii) whether the proposed new anti-avoidance rule in s. 256.1 could be engaged to override this result.