In 2013-0516151I7, a Singapore resident held shares of a Canadian company (Canco) which in turn held real estate in Canada through two partnerships.  The CRA said the look-through provision in Article XIII(3) of the Canada-Singapore Treaty (Gains Article) uses the expression “gains from the alienation of shares of a company…the property of which consists principally of immovable property”; this test refers only to the assets held directly by the company (see also 2008-0304441I7 for similar comments).  However, in the CRA’s view, the immovable property held directly by the partnerships should be included in Canco’s directly-held assets for this purpose, to the extent of Canco’s percentage interest in the partnerships.  This is a debatable interpretation, to say the least.