CRA affirms that the thin cap rules have always applied to the computation of income in s. 216 returns

Following 2013 amendments, the thin cap rules have made specific mention of their application to non-resident corporations which file returns under s. 216 as if they were Canadian residents. CRA has rejected the suggestion that this implies that such corporations were not caught by the thin cap rules before the 2013 amendments.

Neal Armstrong. Summary of 2015-0599161I7 under s. 18(4).