Ian Bradley, Marianne Thompson, Ken J. Buttenham, "Recommended Amendments to the Upstream Loan Rules", Canadian Tax Journal, (2015) 63:1, 245-67.

Narrowness of repayment rule (p. 251)

There are situations in which an upstream loan may cease to represent a synthetic distribution from a...

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Narrowness of s. 90(11) (p. 261)

Subsection 90(11) incorporates only the surplus of the downstream foreign affiliates that are directly or...

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