In the consultation paper, the advisory panel set out the following possible approaches to treaty shopping (paragraph 3.23):

As noted above, certain treaty benefits are afforded to "beneficial owners" who are resident in a treaty country. The CRA has challenged some structures on the basis that the person resident in the treaty country who is

Hyatt hotels Corporation - (2025-TII-02-SC-INTL) with NYSE ticker: H, is an American hotel conglomerate ultimately owned by the Pritzker family of the USA. Hyatt Hotels Corporation is headquartered in Chicago.

According to a website of the hotel chain, 'Hyatt has 52 hotels across Southwest Asia, including 50 in India and two in