Rev. Rul. 55-372

A Canadian or Mexican corporation is held to be a domestic corporation for purposes of qualifying as a Western Hemisphere trade corporation under section 109 of the Internal Revenue Code of 1939 if, as provided in section 141(g) of the Internal Revenue Code of 1939, it is organized and maintained solely for the purpose of complying with the laws of either country as to title and operation of property; and if it is so treated for purposes of section 141 of the Code by a domestic corporation owning or controlling, directly or indirectly, 100 percent of its capital stock. See section 39.141-1(e) of Regulations 118