Other qualifying operational control may establish development and direction even without 50% personal ownership, but the actual agreement must support it. Enterprise treaty nationality has its separate ownership test.
Read the powers rather than the partnership label
Identify who appoints managers, makes operating decisions and can veto material actions. A minority interest is not automatically qualifying or disqualifying. Give the reviewer the complete provisions so a broad promise to participate is not mistaken for actual control.
Counted as a Canadian case, this purchase fails before any other question is reached: nationals of Canada would hold forty-five percent, which is short of the threshold, and no amount of management authority repairs a shortfall in ownership. An established business helps with the real-and-operating and non-marginal questions, but nationality, irrevocable commitment of funds, substantiality and the investor's ability to develop and direct still have to be shown on their own facts. The enterprise must be at least fifty percent owned by nationals of the treaty country, so an equal split leaves no margin, and the applicant must still be able to develop and direct the business despite the partner holding the other half.