CRA publishes look-through/gross-asset approach to characterization of shares of companies holding Canadian real property

CRA has finally released its Round Table response at the 2011 CTF annual conference at which it confirmed that debts could no longer be allocated to specific properties for purposes of determining whether shares are deemed real property for Treaty purposes, and describing the proportionate recharacterization of a portion of shares of a subsidiary as being Canadian real property (based on its relative asset holdings) for purposes of the taxable Canadian property definition.

Neal Armstrong.  Summaries of  28 November 2011 CTF Round Table, Q. 2, 2011-0425901C6 under Treaties - Art. 13 and ITA - s. 248(1) - taxable Canadian property.