15 April 2008 Internal T.I. 2008-0266251I7 - Liechtenstein foundation -- summary under Section 96

The initial concern as to the status of an entity governed by the DRUPA comes from the fact that an entity governed by this legislation is a separate legal entity which is distinct from its partners unless, or to the extent, otherwise provided in a statement of partnership existence and in a partnership agreement. However, an entity governed by the DRUPA has additional characteristics that are similar to the characteristics of a Canadian partnership. ...[T]he attributes of an entity formed under the DRUPA in which its members carry on business in common with a view to profit (in our common law sense) more closely resemble those of a Canadian general partnership under our common law and, as such, an entity governed by the DRUPA would be treated as a partnership for Canadian income tax purposes.