CRA considers that a Canadian Amalco was “incorporated” in Canada

ETA s. 132(1)(a) provides that a corporation is deemed to be resident in Canada if it “is incorporated or continued in Canada and not continued elsewhere.” CRA indicated (perhaps based on Deltona) that where two corporations are amalgamated in Canada, the amalgamated corporation is considered to have been incorporated in Canada. Although a Canadian corporation that is continued outside Canada will not thereafter be considered to have been incorporated in Canada, it will nonetheless be resident in Canada if its central management and control is in Canada - and it will be deemed under s. 132(2) to be resident in Canada in respect of activities carried on by it through any Canadian permanent establishment.

Neal Armstrong. Summary of 27 February 2020 CBA Roundtable, Q.17 under ETA s. 132(1)(a).