Steve Suarez, "Canada Releases Revised Back-to-Back Loan Rules", Tax Notes International, October 27, 2014, p. 357.

Summary Under
Tax Topics - Income Tax Act - Section 18 - Subsection 18(5) - Specified Right
Expansion of permitted security rights under s. 18(5) - "specified right"(p. 362)

Second…[t]he revised ''specified right'' definition appears...

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Summary Under
Tax Topics - Income Tax Act - Section 18 - Subsection 18(6) - Paragraph 18(6)(c)
Introduction of requirement for strong causal connection (p. 361)

Two aspects of the revised secondary obligation definition merit further...

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Summary Under
Tax Topics - Income Tax Act - Section 212 - Subsection 212(3.1) - Paragraph 212(3.1)(c)
Introduction of requirement for strong causal connection (p. 361)

Two aspects of the revised secondary obligation definition merit further...

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Summary Under
Tax Topics - Income Tax Act - Section 212 - Subsection 212(3.1) - Paragraph 212(3.1)(e)
Narrow 25% safe harbour (p. 363)

There are two basic scenarios in which the de minimis exception is intended to provide relief. The first is when...

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