The CRA has made a number of surprising revisions to their previously released interpretation bulletin IT-474R. This article will focus on one of those changes that represents a fundamental shift in the CRA's administrative policy dealing with non-residents of Canada who hold shares (or options for shares) of Canadian corporations and the requirement to obtain a clearance certificate when such corporations are part of a qualifying amalgamation.

Originally published in Tax Topics, No. 1869, January 3, 2008

Please see " CRA Reverses Position on Amalgamations " for important follow-up.

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