Finance states that the B2B rules in s. 15(2.16) are intended to apply mechanically irrespective whether s. 15(2) has been circumvented

Respecting the back-to-back loan rules in s. 15(2.16) et seq., Finance confirmed that “a right should not be considered a ‘specified right’ simply because the right secures debts that the shareholder of the corporation and the corporation itself owe to a financial institution.” Finance also stated:

Where the criteria set out in subsection 15(2.16) are satisfied, the shareholder benefit rules apply to an arrangement or mechanism, even if the facts and circumstances do not actually reveal an intention to circumvent the application of subsection 15(2). The rules are simply a function of the source of funds. This approach is consistent with the underlying technical approach of subsection 15(2), which is not articulated around a "purpose" test.

Neal Armstrong. Summaries of 6 October 2017 APFF Financial Strategies and Instruments Roundtable, Q.13 under s. 18(5) – specified right and s. 15(2.16).