No. Enterprise nationality is assessed through ownership, including the owners behind intermediate entities. Incorporation in Canada and Canadian residence are not substitutes for the relevant treaty-nationality evidence.
Trace the complete structure
Identify individual owners, their citizenship and the applicable percentage ownership. State Department guidance also addresses dual nationals and excludes U.S. lawful permanent residents’ shares when determining the enterprise’s treaty nationality.
Separately document the applicant’s control and qualifying investment. A layered structure can be reviewed, but a parent-company certificate alone does not answer who ultimately owns and directs the U.S. enterprise.
The first review should return a table with one row per ultimate individual owner, showing the proportion held, the citizenship relied on and the document evidencing it. Hypothetical example: a laboratory venture parent is incorporated in Canada, and the review finds that a majority of the ultimate individual ownership sits with holders of a non-treaty nationality. Incorporation in Canada and Canadian residence do not answer the question, and the table makes that visible rather than arguable.
Guidance also addresses dual nationals and excludes U.S. lawful permanent residents from counting toward the treaty ownership requirement, so record each owner status accurately rather than selecting the most convenient nationality. Where an owner nationality cannot be evidenced, leave the row open and mark it, since an assumed entry is what produces advice that later has to be withdrawn.