X Inc. and Y Inc. each hold "tracking units" in a Quebec general partnership ("SENC AB") which, in turn, holds the units of two subsidiary LPs ("SENC A," and "SENC B"). Their A and B units (which are held in different proportions) accord rights to the results of the investment in SENC A and SENC B, respectively. Would CRA consider that X Inc. and Y Inc. hold distinct interests in SENC AB and thereby have distinct ACBs for their A and B units? CRA responded (TaxInterpretations translation):
The CRA does not intend to change its long-standing position to the effect that an interest in a partnership constitutes a single and identical property irrespective whether the capital of the partnership has one or several classes of interest. Consequently, the ACB of the Class A units in the example submitted will not be distinct from the ACB of the Class B units.