Nathan Boidman, "Canada Targets Conduits and Tracking Shares", Tax Notes International, September 17, 2018, p. 1223

Elimination under s. 95(9) of benefit of there being one business with over 5 employees (pp. 1224-1225)

If an FA carries on more than one business...

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Previous use of cell companies for controlled foreign affiliate (CFA) avoidance (p. 1225)

…CFA avoidance arrangements surfaced years ago in...

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