15 August 1990 Income Tax Severed Letter AC59318 - Meaning of "Corporation"

By services, 22 July, 2022
Official title
Meaning of "Corporation"
Language
English
Document number
Citation name
AC59318
Severed letter type
Miscellaneous
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
657050
Extra import data
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"field_release_date_new": "1990-08-15 08:00:00",
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Main text
24(1)                         O. Laurikainen
                              (613) 957-2129

Attention: 19(1)

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 Director Reorganizations and Non-Resident Division Rulings Directorate Legislative and Intergovernmental Affairs Branch