Tax Hyperion, Vol. 18, Issue 4, July-August 2021
A Special Rule for a Specific Instance—Connected and Control
Subsection 186(7) of the Income Tax Act states the following:
Interpretation—For greater certainty, where a provision of this Act or the regulations indicates that the term “connected” has the meaning assigned by subsection 186(4), that meaning shall be determined by taking into account the application of subsection 186(2) unless the provision expressly provides otherwise.
This article will review whether the Income Tax Act outlined specific instances where the broad test of “connected”/”control” does not apply (subsection 186(2)) and investigate the purpose or reasons for providing the exception.
The full publication is accessible here: