Peter Lee, "The Character Substitution Rules", International Tax (Wolters Kluwer CCH), June 2017, No. 94, p. 10

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

Potential embedded purpose test in s. 212(3.6)(a)(ii) (p. 12)

[A]t the 2017 IFA Conference…the Department of Finance…stated that the provision...

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Summary Under
Tax Topics - Income Tax Act - Section 212 - Subsection 212(3.7)

Exclusion of shareholder funding where indirect debt is higher than direct debt (pp. 13-14)

Consider an arrangement in which "Taxpayer" (a...

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