In indicating that where a non-resident payer is a partnership (made up of corporations) and is deemed to be a resident of Canada, the exemption in s. 212(1)(b)(vii) is available, CRA stated:
"Where the provisions of paragraph 212(13)(f) of the Act or subsection 212(13.2) of the Act are applicable in respect of a particular payment such that a non-resident payer of interest is deemed to be a resident of Canada and the payer is a corporation or a partnership, where all of its members are non-resident corporations or another partnership where all of its members are non-resident corporations to which 212(13)(f) of the Act would apply, interest payable in these circumstances will represent 'interest payable by a corporation resident in Canada' for the purposes of subparagraph 212(1)(b)(vii) ... ."