Michael N. Kandev, "Canada Expands Back-to-Back Regime: Examining the Character Substitution Rules", Tax Notes International, June 19, 2017, p.1087

Summary Under
Tax Topics - Income Tax Act - Section 212 - Subsection 212(3.8) - Specified Share

MRPS as example of specified share (p. 1090)

[I]f a Bermuda corporation funds a Luxembourg subsidiary by way of mandatorily redeemable preferred...

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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 dividend declared after particular debt has disappeared (p.1091)

[F]or the character substitution rules to apply, the...

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

Potential non-existence of the situation posited (p. 1092)

[I]t is utterly mysterious how a rent or royalty can be determined, in whole or in...

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Words and Phrases
royalty