In the situation where a corporate general partner of the partnership has no entitlement in the particular year to profits of the partnership because of a preferential share of the individual limited partner with the threshold above which the general partner is entitled to participate not having been exceeded, the corporate partner nonetheless would be considered to have a share of the income of the partnership for purposes of s. 249.1(2), so that the election in s. 249.1(4) would not be available. Before so concluding, CRA stated: