Foreignco owning a vacation property

The CRA confirmed that a non-resident corporation that owns a Canadian vacation property confers a benefit on its non-resident shareholders where the shareholders or non-arm’s length persons use the property. The benefit, as a deemed dividend (214(3)(a)), is subject to Part XIII withholding tax (212(2)). STEP Round Table 2023, question 10 (Tax Topics no 2692 November 21, 2023).

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