- It is understood that the expansion to non-resident controlling individuals or non-arm’s length groups is not aimed principally at CRICs...
- Given the practical infeasibility of complying with the “more closely connected business” (“MCCB”) exception, a replacement relieving...
- The existing s. 212.3(16) exception is simply unworkable where the deemed “controlling” person is a trust beneficiary. In addition, s....
- An example of the (likely, many) anomalies that will occur in the operation of the reorganization rules if the scope of the s. 212.3(1) scoping...
- S. 247(1.1) is circular.
- Para. (b) should refer to payments under either a synthetic equity arrangement or a derivative forward agreement, as the case may be, that are...
- The amendment to s. 152(4)(b)(iii) should be made applicable to taxation years ending on or after March 19, 2019.
- The ss. 15(2) and (2.11) rules should permit PLOI loans to be made by a CRIC to any non-resident person who is a “parent” under the expanded...
- The appropriate consequence of failing to meet the commercial transaction exception solely as a result of the new limitation is that only the...