CRA describes interpretation of s.95(6)(b) post Lehigh
In 2014-0550441C6, the Canada Revenue Agency set out how the Federal Court of Appeal’s decision in the Lehigh Cement case affects the CRA’s interpretation of subsection 95(6)(b) of the Income Tax Act (Canada). “CRA accepts that 95(6)(b) is generally targeted at transactions intended to manipulate the status of a non-resident corporation for the purposes of subdivision i, Division B of Part I of the Act.”