Steve Suarez, "An Analysis of Canada's Latest International Tax Proposals", Tax Notes International, September 29, 2014, p. 1131.

Summary Under
Tax Topics - Income Tax Act - Section 212 - Subsection 212(3.1) - Paragraph 212(3.1)(c)
29 August revised version of description of intermediary ("secondary") debt (pp. 1134-5)

[T]he revised proposal deletes a requirement in the...

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Summary Under
Tax Topics - Income Tax Act - Section 212 - Subsection 212(3.1) - Paragraph 212(3.1)(e)
De minimis rule in s. 212(3.1)(d)

While Finance is to be commended for trying to accommodate typical multinational group borrowing arrangements,...

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Summary Under
Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(9)
Example of operation of PUC reinstatement rule (p. 1142)

[A] Canadian corporation (Cansub)...originally purchased all of the shares of Foreignco...

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