Angelo Nikolakakis, "Lehigh Cement Limited v. The Queen – A Bridge Too FAAAR", International Tax Planning, Volume XIX, No. 1, 2013, p. 1284

Summary Under
Tax Topics - Income Tax Act - Section 17 - Subsection 17(15) - Controlled foreign affiliate

In the course of a submission that it was contrary to the scheme of the Act to apply s. 95(6)(b) to attack indirect loans to a non-resident...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Summary Under
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(n)

In the course of a submission that it was contrary to the scheme of the Act to apply s. 95(6)(b) to attack indirect loans to a non-resident...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Summary Under
Tax Topics - Income Tax Act - Section 95 - Subsection 95(6) - Paragraph 95(6)(b)
Essentially an indirect loan (p.1284)

[I]n essence, the decision involves the potential application of paragraph 95(6)(b) to a taxpayer's...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.