There is an expressed concern that standard documentation for secured guarantees provided by a CCPC for shareholder bank borrowings can trigger the B2B loan rules

It has been suggested that a secured guarantee by a private corporation of a bank loan to its individual shareholder may cause an income inclusion to the individual under the s. 15(2.17) back-to-back loan rules. In order for the bank not to have a specified right, "the key consideration is that the secured property can be used only to repay the shareholder debt." However:

[M]ost guarantees and related security agreements contain broad language that covers not just the present debt but also any future indebtedness of the individual shareholder. Because of this breadth of coverage, a specified right arises, and with it the tax problem.

In addition:

In certain circumstances, a single security document (given by the corporation to the third party [e.g., bank]) can cover both (1) the individual shareholder's loan from the third party and (2) an existing operating loan given by the third party to the corporation. Because the single security document covers more than just the individual shareholder's loan, a specified right arises.

This is a broader interpretation of "specified right" than has been suggested elsewhere (see Lorito).

Neal Armstrong. Summary of Amanda S.A. Doucette and Britney Wangler, “Normal Borrowing by CCPC Owners Can Create an Income Inclusion,” Canadian Tax Focus, Vol. 7, No. 1, February 2017, p. 1 under s. 15(2.17).