Administrative Policy
2015 Ruling 2014-0541951R3 - Foreign Affiliate Debt Dumping
A U.S. corporation will indirectly subscribe for units in a (presumably U.S.) limited liability partnership (FA1) by subscribing for preferred...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(9) - Paragraph 212.3(9)(b) - Subparagraph 212.3(9)(b)(ii) | s. 212.3(9)(b)(ii) PUC restoration for upper-tier QSCs on the payment by a U.S. LLP of a proportionate “dividend” to lower tier CRIC partners | 349 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Corporation | proportionate distribution by LLP treated as dividend | 128 |
| Tax Topics - Income Tax Act - Section 90 - Subsection 90(2) | proportionate LLP distribution to three direct or indirect general or limited partners treated as dividend on single class of shares | 110 |
23 May 2013 IFA Round Table, Q. 6(h)
In response to a query as to whether a s. 212.3(3) dividend substitution election can be made even if there is no qualified substitute corporation...
Articles
Philip Halvorson, Dalia Hamdy, "An Overview of the Foreign Affiliate Dumping Rules", (OBA article), 23 February 2016
Background to introduction of Foreign-Affiliate Dumping rules (p.2)
[P]art of the Advisory Panel’s mandate was to provide recommendations to...
Commentary
Draft s. 212.3(3) provides for a joint election to be made to allow for all or a portion of a dividend that would otherwise be deemed, under s....