That is exactly what we (accountants) have been asking CRA for almost a year now, and CRA won’t give a clear answer. There have been many discussions about it here on this forum (see below, for example). CRA has held webinars, and posted FAQs on their website, and sent representatives to talk about it at various conferences and groups (PBA, CFIB, Chamber of Commerce, etc), but they refuse to state unequivocally what is or is not a partnership for the purpose of the UHT filing. So, use your professional judgement, and cross your fingers. We will get an answer eventually…from the TCC or parliament (if enough people complain to their MPs about it…)