3 December 1992 T.I. 921655 (C.T.O. "Factoring Accounts Receivable Whether Sale or Loan"; Tax Window, No. 26, p. 5, ¶2315)

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Summary Under

Discussion of whether an arrangement between a taxable Canadian corporation and its U.S. wholly-owned subsidiary should be characterized as...

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Summary Under

non-arm’s length terms on sale of trade receivables to sub would indicate that it in fact was a non-arm’s length loan

Canco "sells" its “eligible” trade accounts receivable to its U.S. wholly-owned subsidiary (USco) for their outstanding value, less an arm’s...

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