CRA confirms that debt of a real estate company derives its value from real estate

In the final version of an answer given at the 2012 IFA Roundtable, CRA confirmed that the determination as to whether the value of the shares of a parent are derived directly or indirectly from Canadian real property (so as to be taxable Canadian property) will not be affected by whether its wholly-owned Canadian subsidiary is capitalized only with equity or with debt as well.

Neal Armstrong. Summary of 17 May 2012 IFA Conference Roundtable 2012-0444091C6 under s. 248(1) – taxable Canadian property.