These rules apply where a
corporation that is resident in Canada, which I am calling ``CanCo,'' and that is controlled by a non-resident corporation,
which I am calling ``Parent,'' makes an investment — and that is a defined term — in a corporation not resident in
Canada that is a foreign affiliate of CanCo,
which is to say that is, or immediately after the investment is, a company in
which CanCo has at least a 10 per cent-plus direct or indirect interest. You need a foreign-controlled CanCo that makes an investme
...[+++]nt in a foreign affiliate.