Karen Wilkinson at Deloitte was kind enough to point out to me that the CRA has reversed itself on whether a 116 certificate is necessary when Canadian corporations with non-resident shareholders amalgamate. IT-474R2, issued on December 17, 2007, contained the “new” position. The CRA reissued the bulletin on January 8, 2008, with the old position reinstated. The bottom line is that non-resident shareholders of amalgamating corporations will not be required to obtain a 116 certificate because of the amalgamation.
There’s nothing to see here; move along please.
