Section 134.1 — Income Tax Act: NRO — transition

This section applies to a corporation that was a non-resident-owned investment corporation in a taxation year; 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 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. For the purposes of applying subsections 104(10) and (11) and 133(6) to (9) (other than the definition non-resident-owned investment corporation in subsection 133(8)), section 212 and any tax treaty, a corporation described in subsection (1) is deemed to be a non-resident-owned investment corporation in its first non-NRO year in respect of dividends paid in that year on shares of its capital stock to a non-resident person, to a trust for the benefit of non-resident persons or their unborn issue or to a non-resident-owned investment corporation.