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Technical Interpretation - Internal summary
1 May 2017 Internal T.I. 2015-0624511I7 - 248(1)(e)(ii) of the definition of TCP -- summary under Paragraph (d)
. … [I]ncluding the value of an intercompany receivable balance pertaining to a loan made upstream as a distinct asset when determining the FMV of the wholly-owned lending subsidiary’s assets would result in the double counting… because when carrying out the gross asset value test for the parent corporation the value of the related intercompany payable balance is…ignored while the funds the parent received from the upstream loan would be included as a distinct asset of the parent…. ...
Technical Interpretation - Internal summary
26 November 2009 Internal T.I. 2009-0327551I7 F - Montant pour enfant -- summary under Paragraph 118(1)(b.1)
B ….. If there were three children, either Ms. A or Mr. B could claim the credit under paragraph 118(1)(b.1) in respect of the third child. ...
Technical Interpretation - Internal summary
8 January 2016 Internal T.I. 2015-0604491I7 - mandatory redeemable preferred shares -- summary under Share
. … These corporate documents are not bilateral contracts…. Shares may or may not carry votes, but in respect of the governance of the corporation, typically only shareholders may vote on matters such as the election of the board of directors. ...