In Canadian Forest Navigation Co. Ltd. v. The Queen, 2016 TCC 43, a Canadian parent company (Canco) received dividends from two foreign affiliates and claimed a dividend deduction in s. 113. On audit, the CRA reassessed Canco by denying the dividend deduction. Canco then promptly obtained rectification orders from courts in the foreign countries where the affiliates were resident – without notifying the CRA. These court orders declared that the dividends were not dividends but rather loans. In a subsequent hearing on the sole question whether the CRA was precluded from treating the distributions as dividends, the TCC held that the CRA was not (yet) bound by the foreign rectification orders (see paragraph 24). The foreign court orders would first have to be “homologated” (sanctioned, approved) by a competent court in the province of Quebec, to ensure they do not conflict with the law of rectification in Canada (see paragraphs 11 and 21, and the decision in Pro Swing Inc. v. ELTA Golf Inc., 2006 SCC 52 at paragraphs 13 to 18).