Geoffrey S. Turner, "Transitional Tax Treatment of Grandfathered Upstream Loans – Repayment Deadline Approaching", International Tax (Wolters Kluwer CCH), No. 88, June 2016, p. 7

Summary Under
Tax Topics - Income Tax Act - Section 90 - Subsection 90(9)

Perennial reserve and inclusion mechanism (p. 6)

When the Canadian taxpayer (or the "specified debtor") finally repays the upstream loan or...

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Summary Under
Tax Topics - Income Tax Act - Section 90 - Subsection 90(8) - Paragraph 90(8)(a)

August 19, 2016 repayment deadline for pre-August 20, 2011 loans (p.7)

The paragraph 90(8)(a) carve-out from the upstream loan rules provides...

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Summary Under
Tax Topics - Income Tax Act - Section 39 - Subsection 39(2.1)

Purpose of eliminating FAPI whipsaw mismatch (e.g., where US dollar upstream loan) due to sub’s taxable capital gain or allowable capital loss...

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