1 February 1991 T.I. (Tax Window, Prelim. No. 3, p. 27, ¶1115)

Where the taxpayer, who holds all the preference shares of a holding company which in turn holds all the shares of Opco arranges to borrow money...

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An individual, who holds the preference shares of a holding company whose common shares are held by his children, borrows money at 13% and lends...

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