CRA treats the activities of a corporation as being transparent for Indian Act purposes

CRA found that the portion of capital gains realized by status Indians on their sale of shares of a corporation - whose head office and management were based in a reserve – that was exempt, should be determined by the portion of the management and other income-generating activities located on the reserve.

Neal Armstrong. Summary of 4 February 2015 Memo 2014-0520721I7 under Indian Act, s. 87.