2005 Ruling 2005-0133041R3 - Investors not dealing non-arm's length -- summary under Paragraph 251(1)(c)

In the context of an issue as to whether shares of a non-resident corporation were taxable Canadian property, CRA ruled that the winding-up of the corporation and related transactions by a group of shareholders would not, by itself, cause them to be considered to be not dealing arm's length with each other or with the corporation and its subsidiaries.