After indicating that a corporation that was wholly-owned by a partnership was related to the corporation which, along with its wholly-owned subsidiary, held all the partnership interests, the Directorate went on to state:
[W]here the partners do not solely comprise of a corporation and its wholly-owned subsidiary, the partnership agreement governing that particular partnership should be taken into account in determining who controls a corporation when a partnership owns shares in a corporation. The partnership agreement and the equity interest of the members must be examined to determine which member(s) of the partnership can exercise voting rights in respect of the shares of the corporation. In the case of a limited partnership … it is usually the general partner that can exercise these rights.