19 January 2007 Internal T.I. 2006-0216451I7 F - Fondation privée investissant dans une S.P. -- summary under Section 96

In the context of whether a private foundation could have its registration revoked for carrying on business through a foreign partnership that was governed by the Delaware Revised Uniform Partnership Act (DRUPA), the Directorate confirmed its position that the foreign entity status of such an entity (or of an entity governed by the DRULPA) did not preclude it from being a partnership.