7 October 2005 APFF Roundtable Q. 1, 2005-0140881C6 F - Acquisition of Control - Foreign Corp. - Losses -- summary under Paragraph 111(4)(c)

As s. 249(4) does not apply to a non-resident corporation that does not have a permanent establishment in Canada and whose control is acquired by another non-resident corporation, ss.111(4)(c) and (d) will not apply to shares of a taxable Canadian corporation held by the first non-resident corporation.