Derek G. Alty, Brian M. Studniberg, "The Corporate Capital Structure: Thin Capitalization and the ‘Recharacterization' Rules in Paragraphs 247(2)(b) and (d)", Canadian Tax Journal, (2014) 62:4, 1159-1202.

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Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2)

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Tax Topics - Treaties - Income Tax Conventions - Article 9

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