2000 Ruling 2000-0028343 - Foreign Prop. held by Registered Investment -- summary under Paragraph 108(2)(b)

It had been accepted in a previous ruling that the holding of each of a number of foreign incorporated businesses through a separate Canadian holding company would thereby avoid exceeding the 10% threshold in s. 108(2)(b)(v). The amendment approved the transfer by the Canadian holding companies to a newly-incorporated foreign holding company of all the shares of the foreign companies, so that the resulting structure entailed a series of Canadian holding companies all holding shares of one foreign holding company which, in turn, held the different U.S. operating companies.