Emergis Inc. v. The Queen, 2021 TCC 23, rev'd 2023 FCA 78 -- summary under Subsection 20(12)

Summary Under
Tax Topics - Income Tax Act - Section 20 - Subsection 20(12)
U.S. withholding tax applicable to a tower structure did not generate a s. 20(12) deduction

The taxpayer (“Emergis”), a Canadian public company, financed its acquisition of an arm’s length U.S. operating company through a "tower...

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Words and Phrases
in respect of