• Partnership with a permanent establishment

    Attention

    Warning:

    This information may not apply to the current year. Check the content carefully to ensure it is applicable to your circumstances.

    End of attention

    Even if the CFC did not carry on business at or through a permanent establishment, the CFC will satisfy this condition if any partnership in which it is a member carried on business at or through a permanent establishment in the country of residence of the CFC.

    Did the CFC directly or indirectly through a partnership carry on business through a permanent establishment in its country of residence?

    Yes

    Read on.

    No

    The CFC has failed the active income test. Go straight to part 3.

    Last modified: 05 Dec 2006QC 17522