8 December 2015 External T.I. 2015-0613401E5 F - Attribution Rules -- translation

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This translation was prepared by Tax Interpretations Inc. The CRA did not issue this document in the language in which it now appears, and is not responsible for any errors in its translation that might impact a reader’s understanding of it or the position(s) taken therein. See also the general Disclaimer below.

Principal Issues: Will subsection 74.4(2) apply in the scenarios described?

Position: No in the first scenario. Probably in the second scenario....

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