To secure benefits under tax treaties, certain entities or persons may be required to attest or have certified that they are not fiscally-transparent for tax purposes. The Canada Revenue Agency (CRA) will only issue a Canadian Certificate of Residency to a taxpayer if it is satisfied that the taxpayer is a resident of Canada for tax purposes by virtue of being liable to tax in Canada. That test is applied to the taxpayer (whether it be an individual, corporation or trust) in their own right without reference to the tax liability of others. The CRA does not issue Canadian Certificates of Residency to fiscally transparent entities or other persons not resident in Canada under Canada’s domestic tax laws and its tax treaties.