In the course of a submission that it was contrary to the scheme of the Act to apply s. 95(6)(b) to attack indirect loans to a non-resident...
In the course of a submission that it was contrary to the scheme of the Act to apply s. 95(6)(b) to attack indirect loans to a non-resident...
Essentially an indirect loan (p.1284)
[I]n essence, the decision involves the potential application of paragraph 95(6)(b) to a taxpayer's...