Dear Sirs:
Re: Definition of "Small Business Corporation"
This is in reply to your letter of October 4, 1991 wherein you request our views whether, in the definition of small business corporation in subsection 248(1) of the Income Tax Act (the "Act"), the word "corporation" in the phrase 'corporation related to it includes both the singular and plural.
In particular you are concerned that the use the of the word "principally", in the amendment proposed by Bill C-18 to the definition of small business corporation in subsection 248(1) of the Act, may dictate a reading of the phrase corporation related to it' in the singular and not in the plural.
It is our view that within the context of the amended definition of small business corporation as proposed in Bill C-18 the phrase corporation related to it would include both the singular and plural.
We trust this will be of assistance to you.
Yours truly,
for DirectorBusiness and General DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch