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Unformatted text preview: proach when applying the ownership tests in articles xxix a(2)(d) and (e) (discussed below). The Cra recommended that the technical explanation reflect this interpretation. 94 n c anadian tax journal / revue fiscale canadienne ( 2009) vol. 5 7 , n o 1 and the recipient, the fiscally transparent us entities should be ignored in determining the qualifying person. For example, assume that a us-resident individual owns a us limited liability company (LLC), which in turn owns a us C corporation, and the us C corporation wishes to obtain treaty benefits in respect of the Canadian-source income it receives. in this case, the us individual is treated as the us C corporation’s owner for the purposes of article xxix a(2)(d). although this treatment constitutes a logical extension of the lookthrough principles under article iV(6), it is still a welcome clarification from a Canadian perspective. article X XIX a(2)( e ): ownership Test under article xxix a(2)(e), a company or trust that is a resident of Canada or the united states is entitled to treaty benef...
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