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15 August 2012 External T.I. 2012-0443581E5 - Shareholder Loans -- attach -- Subsection 15(2.6)

15 August 2012 External T.I. 2012-0443581E5 - Shareholder Loans -- attach -- Subsection 15(2.6)

FIFO presumption; concern re year end straddles

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