Nik Diksic, Sabrina Wong, "Cross-Border Lending Practices", 2017 CTF Annual Conference draft paper

Summary Under

Whether s. 212(3.6) applies prospectively (p. 6)

[I]f the particular debt or other obligation is issued in Year 1, but the dividend obligation...

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Summary Under

Whether a common share can be a specified share (p. 8)

[I]t seems reasonable to question whether a common share can, in certain circumstances,...

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Summary Under

Cannot benefit from ultimate funder withholding rate if immediate funder rate is higher (p. 11)

Consider … where NR1 (treaty country [with 10%...

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Summary Under

Loss of specified right exclusions where a NR bank lends to Canco through a non-resident affiliate (pp. 12-13)

NR1 borrows from a third-party bank...

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Summary Under

Interest deductibility where co-borrower arrangements (p. 20)

U.S.-styled credit agreements involving both U.S. and Canadian borrowers within the...

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