CRA releases its convertible debenture ruling
28 August 2013 - 8:52am
CRA has released its 2012 ruling that the semi-annual interest on a plain vanilla convertible note was not participating debt interest, so that it was not subject to Part XIII tax when paid to an arm’s length non-resident holder.
Neal Armstrong. Summary of 2012 Ruling 2011-0418721R3 under s. 212(3) – participating debt interest.