PWC, "Bill C-29 significantly expands back-to-back rules", Tax Insights PWC International Tax Services, Issue 2016-53, 16 November 2016

Summary Under
Tax Topics - Income Tax Act - Section 212 - Subsection 212(3.4)

Example illustrating key difference between the existing and amended rules in a situation Canco and 4 related non-residents (NR1, NR2, NR3 and...

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Summary Under
Tax Topics - Income Tax Act - Section 212 - Subsection 212(3.9) - Paragraph 212(3.9)(b) - Subparagraph 212(3.9)(b)(ii)

Difficulty for the taxpayer in determining ultimate licensing structure (pp. 3-4)

The new back-to-back royalty rules...apply in certain...

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Summary Under
Tax Topics - Income Tax Act - Section 212 - Subsection 212(3.91)

Potentially punitive effect of CRA not accepting allocation (p.4)

If the Minister does not accept that the taxpayer's allocation is reasonable,...

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