2002 Ruling 2001-0115933 - STOCK OPTIONS CORPORATE PARTNERSHIP -- summary under Paragraph 7(1)(a)

Where two trusts and a corporation are the limited partners and a second corporation is the general partner of a partnership, benefits under a stock option plan set up in respect of the partnership will be covered by ss.7 and 110(1)(d). "There are no agreements in place which limit the employment relationship of any of the employees of the partnership to any of the corporate or trust partners. Consequently, each of the employees of the partnership are considered to be employees of each of the partners of the partnership for the purposes of section 7."