3 November 2008 External T.I. 2008-0278431E5 F - Déménagement hors Canada du siège soc. de société -- summary under Paragraph (a.1)

In the context of a general discussion of consequences of a Canadian corporation with a start-up Canadian manufacturing operation in Canada, as well as research and development performed there, becoming a non-resident of Canada pursuant to s. 250(5), CRA stated:

[A] non-resident corporation's Part I tax could be reduced by an investment tax credit for research and development expenses incurred in Canada if the corporation carries on business in Canada, the research is related to that business and the corporation satisfies the conditions provided in the Act for claiming such a credit.

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