iIn finding that the income allocated to the taxapyer through two tiers of partnerships continued to be attributable to the underlying resource properties of the second tier partnershp for purposes of s. 66.7(10)(j), Hogan J stated (at para. 45):
In a tiered partnership, the source and location of income is preserved through each level of partnership until the income is ultimately recognized by, and taxed in the hands of, the corporate or individual partners. This is supported by subsection 102(2)... .