Administrative Policy
12 February 2018 interpretation 167422R
qualifying subsidiary definition can be applied iteratively
In a wholly-owned group, there are two stacks of four corporations beneath a common Holdco. CRA concluded that the “qualifying subsidiary” definition could be applied iteratively, so that the two bottom (Canadian) corporations will be able to elect with each other under s. 156 as being closely related to each other and members of a qualifying group under s. 156(1).
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 156 - Subsection 156(1) - Qualifying Group | two Canadian sisters can be closely related for GST/HST purposes through multiple stacked NR corporations above them | 301 |
11 October 2017 Interpretation 181628
great-grandchild held on a 50-50 basis
A corporation which was held on a 50-50 basis by two wholly-owned grandchildren of A was closely related to A as well as to another wholly-owned grandchild of A held through another chain.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 128 - Subsection 128(1) - Paragraph 128(1)(a) | a corp. (F) held 50-50 by two 100% grandchildren of A was closely related for ETA purposes to A and to H (another 100% grandchild of A) | 276 |