Brett Anderson, Daryl Maduke, "Practical Implementation Issues Arising from the Foreign Affiliate Dumping Rules", 2014 Conference Report, (Canadian Tax Foundation), 19:1-49

Summary Under
Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(1.1)
PUC offset filing deadline could arise before acquisition of control (p. 19:31)

The policy reasons for implementing a one-year time frame within...

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Summary Under
Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(14) - Paragraph 212.3(14)(a)
Example of "hollowing out" transaction: subsequent sale of good assets by subject corp. (p. 10)

The explanatory notes issued by Finance with...

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Summary Under
Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(19)

s. 212.3(19) can extend to common shares (p. 16)

[C]ommon shares may also be caught if their participation rights are contractually restricted by...

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Summary Under
Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(1)

FAD rules apply only to 1st tier FA investments (p. 34)

[A]s a result, certain transactions with similar economic results Can give rise to an...

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Summary Under
Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(2)
Two interpretations of subject corporation acquired under earnout agreement: PV all investment obligations at investment time; or succession of...

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Summary Under
Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(7)

Potential conflict between NR parent and 3rd party Cdn. investor re application of s. 212.3(7)(a) (p.29)

Figure 16 illustrates an example where...

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Summary Under
Tax Topics - Income Tax Act - Section 227 - Subsection 227(6.2)
227(6.2) does not eliminate deemed dividend for non-FAD purposes (p.22)

[S]ubsection 227(6.2) requires the CRA to accept late-filed paragraph...

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