GST/HST Memorandum 14-7 Closely Related Corporations June 2023

S. 132(2) does not deem the PE to be a resident person or a closely related person

8. Subsection 132(2) provides that where a person that is not...

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Notwithstanding s. 132(3), resident can be closely related re activities of its foreign PE

9. Subsection 132(3) provides that where a person who...

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S. 128(1) rule generally does not apply where shareholder is non-corporate

25. In general, subsections 128(1) and (2) do not apply where a person...

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Recap of s. 128(1.1)

29. In other words, in order for a person (or a group of persons) to be considered to hold qualifying voting control of a...

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Separate class vote accorded by CBCA not taken into account

31. [C]ertain matters listed in subsection 176(1) of the Canada Business Corporations...

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Example 4

• A and B each owns 50% of the shares of C, which wholly-owns D, but all of the voting rights attached to the shares of D are held by...

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Example 10

• A and B (a qualifying subsidiary of A) each hold 50% of the full voting rights and 50% of the ownership for the shares of C, so that A...

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