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Tax Interpretations
Canadian tax interpretations and transactional implications
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CRA finds that the connection test in XXIX-A(3) of U.S. Treaty can be satisfied by funding interest to a non-qualifying U.S. parent, on a loan whose use had nothing to do with a connected Canadian business, out of the cash flows generated by that business
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(Your name) has forwarded "CRA finds that the connection test in XXIX-A(3) of U.S. Treaty can be satisfied by funding interest to a non-qualifying U.S. parent, on a loan whose use had nothing to do with a connected Canadian business, out of the cash flows generated by that business" - Tax Interpretations
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