29 August 2000 Internal T.I. 2000-0023187 F - Société privée sous contrôle canadien -- summary under Subparagraph 251(2)(b)(i)

A corporation (Opco), the voting rights of which were owned as to 1/3 by an individual and as to 2/3 by a limited partnership of which the general partner (C Ltd.) was a wholly-owned subsidiary of B Ltd., which was wholly-owned by a public corporation, (A Ltd.). After noting that “[w]here … a limited partnership has only one general partner, the Agency's position is that the general partner generally has control of the limited partnership,” CRA indicated that C Ltd. thus controlled Opco, and that the “ultimate control” of Opco, as described in Parthenon, was held by A Ltd. Thus, since Opco was controlled by a public corporation, it was not a CCPC.