Income Tax Act

Marginal note:NRO — transition

• 134.1 (1) This section applies to a corporation that

  • (a) was a non-resident-owned investment corporation in a taxation year;

  • (b) is not a non-resident-owned investment corporation in the following taxation year (in this section referred to as the corporation’s “first non-NRO year”); and

  • (c) elects in writing filed with the Minister on or before the corporation’s filing-due date for its first non-NRO year to have this section apply.

• Marginal note:Application

  (2) A corporation to which this section applies is deemed to be a non-resident-owned investment corporation in its first non-NRO year for the purposes of applying, in respect of dividends paid on shares of its capital stock in its first non-NRO year to a non-resident person or a non-resident-owned investment corporation, subsections 133(6) to (9) (other than the definition non-resident-owned investment corporation in subsection 133(8)) and section 212 and any tax treaty.