91 C.R. - Q.30

Where a Canadian subsidiary guarantees the loan obligations of its foreign parent, the determination of the amount of benefit is a question of fact.

Where a Canadian subsidiary guarantees the loan obligations of a foreign parent, s. 69(3) will apply to deem the amount that would have been reasonable in the circumstances, if the corporations had been dealing at arm's length, to have been received or receivable by the Canadian subsidiary.