Dean Kraus, John O’Connor, "Foreign Affiliate Dumping: Selected Issues", 2017 Annual CTF Conference draft paper

Summary Under
Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(1) - Paragraph 212.3(1)(a) - Subparagraph 212.3(1)(a)(ii)

Example of application of s. 212.3(1)(a)(ii) to loan made by resident individual’s company to a CFC held by his U.S. brother through a US...

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Summary Under
Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(1) - Paragraph 212.3(1)(b)

Relevance of partnership agreement to control of corporations held by a limited partnership (p. 10)

[T]he “very capacity to act” [fn 50: Duha...

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Summary Under
Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(18) - Paragraph 212.3(18)(a) - Subparagraph 212.3(18)(a)(i)

Failure of drop-down by Amalco (resulting from Buyco and Canadian target) to subsidiary of target to satisfy s. 212.3(18)(a)(i) (pp. 18-19)

[A]...

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