A trust which is factually non-resident but which is deemed to be resident in Canada under s. 94(3) controls a Canadian corporation. Would the corporation be considered Canadian controlled for purposes of the definition of Canadian-controlled private corporation?
CRA indicated that as s. 94(3)(a) does not deem the trust to be resident in Canada for purposes of applying the CCPC definition, the fact that the trust is deemed resident in Canada to the extent specified in s. 94(3)(a) will not result in the corporation being a CCPC.