24 November 2015 CTF Annual Roundtable, Q.10

Policy Tabs

Summaries

Summary Under

application where no gain on shares/non-application to loss-shifting transactions

Points respecting proposed s. 55(2.1)(b)(ii) included:

The purpose test in s. 55(2.1)(b)(ii) could apply even if the dividend does not satisfy...

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Summary Under

foreign-currency debt to Canco translated at historical rate

Based on s. 261(2), the amount of U.S.-dollar denominated debt is to be measured for thin cap purposes in Canadian dollars based on the FX rate at...

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