Question: A Canadian public company ( i . e . parent company ) holds 1 0 0 % of the shares of a company Bermuda (

A Canadian public company (i.e. parent company) holds 100% of the shares of a company
Bermuda (i.e. subsidiary).
The Canadian company receives a dividend payment from its
subsidiary in Bermuda and pays out a dividend to its Canadian public shareholders.
Assume the following tax treatments:
The tax law in Bermuda does not tax business income
The tax law in Canada allows a section 113 deduction for dividends from wh foreign subsidiaries
Would you consider the business structure to lead to tax avoidance? Explain!

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