Mark Coleman, "Treaty Shopping and Back-to-Back Loan Rules", Power Point Presentation for 28 May 2015 IFA Conference in Calgary.

Summary Under
Tax Topics - Income Tax Act - Section 212 - Subsection 212(3.1) - Paragraph 212(3.1)(c)

Where CanCo receives an interest-bearing loan from its immediate parent (Treaty Co 1), which is funded by equity from the parent (Non-Treaty Co...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Summary Under
Tax Topics - Income Tax Act - Section 212 - Subsection 212(3.1) - Paragraph 212(3.1)(d)

If a loan by U.S. Parent to its "grandchild" Canadian ULC sub (held e.g.,, through a C-Corp sub) is funded by a loan by an LLC sub ("Opco") of...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Summary Under
Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Foreign Accrual Tax

Non-Treaty Co makes a non-interest-bearing loan to its parent (Treaty Co) to fund an interest-bearing loan to the Canadian-resident parent of...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.