Charles Taylor, "Foreign Affiliate Dumping Developments", International Tax, No. 72, October 2013, p. 9

Summary Under
Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(7)
Adverse thin cap impact of automatic grind under s. 212.3(7) (p. 10)

While PUC reduction is generally preferable to a withholding tax cost, there...

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Summary Under
Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(9)
Potential desirability of triggering withholding tax under s. 84(1) (p. 10)

Taxpayers should be sensitive to the potential for double taxation...

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