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The deeming by s. 212(3.1) of Part XIII tax on a back-to-back loan to be payable by the lender to the intermediary rather than by the intermediary may result in loss of a FAT deduction where the loan from the intermediary generates FAPI
(Your name) has forwarded "The deeming by s. 212(3.1) of Part XIII tax on a back-to-back loan to be payable by the lender to the intermediary rather than by the intermediary may result in loss of a FAT deduction where the loan from the intermediary generates FAPI" - Tax Interpretations