| 24(1) | 5-9318 |
| O. Laurikainen | |
| (613) 957-2129 | |
| Attention: 19(1) |
August 15, 1990
Dear Sirs:
Re: Meaning of "Corporation"
This is in reply to your letter of December 18, 1989.
We agree with your view that an incorporated company created under the corporate statutes of a foreign jurisdiction is,not withstanding that its shareholders have unlimited liability for the debts of the company, a corporation within the meaning of section 248 of the Income Tax Act (the "Act"). Accordingly, it is possible for such a corporation to be a foreign affiliate of a taxpayer resident in Canada within the meaning set out in paragraph 95(1)(d) of the Act.
We trust this is the information you require.
Yours truly,
for DirectorReorganizations and Non-Resident DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch