Chc Sold!!!

[smickey]

Here's some additional info on OETC. Para 14a would suggest that Cdn employees will still qualify for OETC, assuming CHC's headquarters stays in Canada. But nothing is ever cut and dry when it comes to interpreting tax regulations, so who knows what the ruling will be.....

Revenue Canada Website states:

13. A specified employer, for OETC purposes, is described in subsection 122.3(2) as:
(a) a person resident in Canada (see ¶ 14);
(b) a partnership in which persons resident in Canada or corporations controlled by persons resident in Canada own more than 10% of the aggregate fair market value of all interests in the partnership; or
(c) a corporation that is a foreign affiliate (as defined in subsection 95(1)) of a person resident in Canada.

See ¶ 16 regarding certain services an individual performs for which no OETC may be claimed on the employment income received.
¶ 14. Subject to subsection 250(5), a specified employer that is a corporation is generally considered to be a resident of Canada if:
(a) its central management and control are located in Canada; or
(b) it falls within the criteria set out in subsection 250(4) which deems a corporation to be resident in Canada throughout a taxation year.

For further information on the residency of a corporation, see the current version of IT-391, Status of Corporations.

IT 391 states:

Corporate Residence
15. The common law has generally established that a corporation is resident in the country in which its central management and control is exercised (DeBeers Consolidated Mines Limited v. Howe, (1906) A.C. 455). Usually management and control exists where the members of the Board of Directors meet and hold their meetings. However, if the Board of Directors of a company does not in fact exercise its powers, and the management and control of the company is actually exercised by some other party, such as the directors of its parent company or its principal shareholder, who are resident in another country, the company will be resident in that other country (Unit Construction Co. Limited v. Bullock, (1960) A.C. 351).