ultimate control

29 August 2000 Internal T.I. 2000-0023187 F - Société privée sous contrôle canadien -- summary under Canadian-Controlled Private Corporation

A corporation (Opco), the voting rights of which were owned as to 1/3 by an individual and as to 2/3 by a limited partnership of which the general partner (C Ltd.) was a wholly-owned subsidiary of B Ltd., which was wholly-owned by a public corporation, (A Ltd.).

By services, 28 November, 2015

Parthenon Investments Ltd. v. Canada (National Revenue), 97 DTC 5343 (FCA) -- summary under Canadian-Controlled Private Corporation

All the voting shares of the taxpayer were owned by a Canadian corporation all of whose voting shares were owned by a U.S. corporation. All the shares of the U.S. corporation were owned by two Canadian-resident corporations.

In finding that the taxpayer was a Canadian-controlled private corporation, MacGuigan J.A. stated (at p. 5345):

ultimate control

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