The CRA recently released Interpretation Bulletin IT-474R3 (“Amalgamations of Canadian Corporations”). One of the big changes relates to the requirement to obtain a certificate under section 116 of the Income Tax Act. Previously, the CRA took the position that a non-resident shareholder of an amalgamating corporation was not required to obtain such a certificate (see ¶45 of the old bulletin). The CRA has changed that position in the new bulletin: non-resident shareholders will now be required to obtain a certificate, much to the delight, no doubt, of the already-swamped CRA workers in the trenches who deal with the requests for certificates.
