Sabrina Wong, "Bill C-29 Amendments to the Back-to-Back Rules", International Tax, Wolters Kluwer CCH, December 2016, No. 91, p. 5

Summary Under
Tax Topics - Income Tax Act - Section 212 - Subsection 212(3.2)

Allocation under s. 212(3.2) formula of interest to ultimate funder in excess of actual interest to it (p. 7)

Essentially, the formula allocates...

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Summary Under
Tax Topics - Income Tax Act - Section 212 - Subsection 212(3.9) - Paragraph 212(3.9)(b) - Subparagraph 212(3.9)(b)(ii)

Likely insufficient information for Canadian taxpayer to evaluate arm’s length test (p.9)

[I]t appears that the "one of the main purposes" test...

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Summary Under
Tax Topics - Income Tax Act - Section 212 - Subsection 212(3.6) - Paragraph 212(3.6)(a)

Potential application to common shares (p. 10)

[T]he Character Substitution Rules…generally apply where a "relevant funder" has an obligation to...

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