CRA will not provide a list of the foreign entities that it considers to be of particular entity types

CRA is unwilling to provide the equivalent of the HMRC table listing entities in a wide range of jurisdictions that it considers to be opaque or transparent for UK tax purposes: CRA considers that its two-step approach to entity classification needs to be applied on a “case-by-case basis” in light inter alia of the application of the foreign law to the documentation governing the particular entity or arrangement.

However, CRA will entertain ruling requests based on complete taxpayer submission as to their analysis of the application of the two-step approach to the relevant documentation submitted by them.

Neal Armstrong. Summary of 17 May 2022 IFA Roundtable, Q.8 under s. 248(1) – corporation.