12 November 2002 TEI Roundtable Q. 14, 2002-0173955 - Income From Services -- summary under Paragraph 95(2)(b)

S.95(2)(b) would apply where a Canadian subsidiary of a Canadian financial institution, which provides management services to pension funds but is not licensed to carry on an investment management business outside Canada, appoints a controlled foreign affiliate of its parent as a sub-adviser for non-Canadian securities under a bona fide subcontract, comparable to that which the foreign affiliate would enter into in providing services to arm's-length parties.