Jack Bernstein, Francesco Gucciardo, "Canada-U.S. Hybrid Financing – A Canadian Perspective on the U.S. Debt-Equity Regs", 26 September 2016, p. 1151

Summary Under
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(a) - Subparagraph 95(2)(a)(ii) - Clause 95(2)(a)(ii)(B)

Recharacterization rules under Code s. 385 (p.1152)

Most fundamentally, the proposed regulations would automatically treat what would otherwise be...

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Summary Under
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c)

Description of financing by U.S. lender of Canadian real estate company (Canadian RealCo) through hybrid debt (pp. 1158-1159)

[I]nstead of [the...

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