CRA acknowledges USA relevance to deemed control branch of CCPC definition
3 September 2014 - 9:52am
Email this ContentCRA has acknowledged that its previous position in ITTN no. 44 that "unanimous shareholder agreements are not to be considered in applying … the definition ‘Canadian-controlled private corporation’" in s. 125(7) para. (b), "cannot be reconciled with the interpretation … by the Courts in Bagtech."
Neal Armstrong. Summary of 2014 CALU Roundtable, Q. 3, 2014-0523301C6 under s. 125(7) – Canadian-controlled private corporation.