Forco 1 is held through three stacked Canadian partnerships (the bottom one, “CanGP 3”) by two taxable Canadian corporations (Canco 1D and Canco 1A) which, in turn, are indirect wholly-owned subsidiaries of a non-resident parent (“Parent”). Forco 1, which is unlimited liability company resident in Foreign Country 3, wholly owns Forco 2, which is resident in Country 3 and wholly-owns Forco 3, which is a limited liability company resident in Foreign Country 2. Parent wholly owns Forco 4, which is a limited liability company resident in Country 2. Forco 5 is a private limited liability company resident in the Netherlands and is directly owned by Forco 2, Forco 3 and Forco 4.
In the factual description, Forcos 1, 2 3 and 5 are described as a CFA of CanGP 3 and also as a FA of Canco 1A and Canco 1B by virtue of s. 93.1(1).