Words and Phrases - "reasonably regarded"

a
93
b
44
c
87
d
58
e
43
f
32
g
20
h
15
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77
j
2
k
3
l
32
m
63
n
29
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42
p
83
q
3
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80
s
96
t
48
u
16
v
11
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25
y
2

2 April 2026 External T.I. 2021-0917901E5 - Application of subsection 212.3(16)

Summary Under
Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(16)
how to apply the more closely-connected test in s. 212.3(16) where Canco has overlapping officers with its non-resident parent

A US-resident public company (US Pubco) wholly owns US Holdco, which in turn wholly owned USCo, as well as Canco, which has foreign subsidiaries....

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Words and Phrases
reasonably regarded