“Foreign company” definition of section 9D of ITA

“foreign company” means any-

 

(a)     cell or segregated account contemplated in the definition of “protected cell company”;

 

(b)     protected cell company to the extent that-

 

(i)      specified assets of that company are not segregated into structurally independent cells or segregated accounts as contemplated in paragraph (a) of the definition of ‘protected cell company’; or

 

(ii)     specified assets and liabilities of that company are not linked or attributed to cells or segregated accounts as contemplated in paragraph (b) of the definition of ‘protected cell company’; or

 

(c)     foreign company, as defined in section 1, other than a protected cell company;