Apparently there are a few different versions in the family of Mitchell M16'ish rifles, for instance, here are some great images of a Mitchell M16A3CAR (and its markings) that is strikingly similar to the OP's:
http://www.icollector.com/Mitchell-Arms-Model-16A3CAR-Semi-Automatic-Rifle_i21582386
Here are some great images of a Mitchell M16A3/22:
http://www.icollector.com/Mitchell-Arms-Model-16A3-22-Cal-Semi-Auto-Rifle_i26868341
I agree that none of the rifles we are discussing might seem like an obvious variant of an M-16 because of the blatant differences in design and parts interchangeability etc. However, if the CCC specifically says that any model and its variants are to be included as variants of the M-16 - my concern was that the SB would potentially be considered a variant under Canadian law.
So, if:
- Arms Corporation of the Philippines = Armscor = ACP; and
- ACP makes the same gun under Mitchell/Squires Bingham name brands.
The big questions that remain (to me) are:
1. Since Mitchell M16A1/22's are listed as variants, are the Mitchell M16A3/22's also considered variants or not? If so, then the Squires Bingham (and all other brand) labelled versions would be in danger of also being legally considered a variant.
2. Since it looks like the Mitchell M-16A-1/22, Mitchell M-16/22, Mitchell CAR-15/22, and (iv) AP74 Auto Rifle were all made by Jager - are only Jager made M16/22's intended to be variants by law? If so, then the ACP made Squires Bingham (and all other brand) labelled versions would be safe.