Allgood, "Recent Developments in Asset-Backed Securitization", 1993 Conference Report, c. 16

Summary Under
Tax Topics - Income Tax Act - 101-110 - Section 102 - Subsection 102(2)

Discussion of custodial arrangements giving unequal interests in choses in action.

Summary Under
Tax Topics - Income Tax Act - Section 9 - Timing

Critique of Revenue Canada's position on the distinction between the sale of receivables, and loan secured with receivables.

Summary Under
Tax Topics - Income Tax Regulations - Regulation 7000 - Subsection 7000(1) - Paragraph 7000(1)(b)

Discussion of application of interest accrual rules to arrangements creating unequal interests in personal property.