4 April 2011 External T.I. 2010-0388741E5 F - Société quittant le Canada -- summary under Subsection 250(5.1)

In the course of a general discussion of the continuance of a corporation from Canada to Europe, CRA stated:

A corporation that is continued may, depending on the circumstances, be considered to have ceased to reside in Canada. Indeed, under subsection 250(5.1), a corporation continued in another country would be considered to be incorporated in the other country from the date of continuance, and would no longer be deemed to be resident in Canada under paragraph 250(4) from that date. If, following its continuance, a corporation ceased to reside in Canada, it would generally no longer be required to file Canadian tax returns for taxation years subsequent to the change of residence (assuming no activity or income from Canadian sources).

CRA went on to discuss the application of ss. 128.1(4) and 219.1.

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