Subsection 139.1(1) - Definitions
Mutual Holding Corporation
Administrative Policy
25 September 2014 T.I. 2012-0451411E5 F - Mutual Holding Corporation
"holding" must be direct holding
Does a mutual corporation qualify as a mutual holding corporation if it holds shares of the insurance corporation indirectly? After quoting from the mutual holding corporation definition, CRA stated (TaxInterpretations translation):
[T]he legislator contemplated the direct holding and not an indirect holding of shares of the capital stock of the insurance corporation.