1 December 1992 Memorandum (Tax Window, No. 27, p. 11, ¶2352; October 1993 Access Letter, p. 475)

Where a non-treaty country subsidiary of a Canadian corporation manufactures or process goods outside Canada with no purchasing or processing of...

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A list of nine criteria for determining whether a Canadian corporation is an independent agent of a U.S. corporation for purposes of Article V(7)...

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