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. … Regardless, the outcome in Nortel finally confirms that interest should no longer be deductible under paragraph 20(1)(c) unless otherwise provided for in the plan. ...

. … The specified factor of 0.35 operates as a form of rough justice, but does not distinguish between different rates of tax…. ...

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MNR, [fn 6: 70 DTC 1208 …]… [R]oland St-Onge QC compared the legal status of a GmbH under German law with the legal status of a corporation under Canadian law. ...

PWC, "Tax Insights: Excessive interest and financing expenses limitation (EIFEL) regime", Issue 2022-06, 15 February 2022-- summary under A Summary Under Tax Topics- Income Tax Act- Section 18.2- Subsection 18.2(1)- Adjusted Taxable Income- A Double-deductions of non-capital losses Item A in the ATI formula is reduced by the non-capital loss and net capital loss generated for the current year – yet if these losses are applied in a future year, there is no consequential ATI adjustment for that subsequent year (except for the partial addback of the portion of a non-capital loss that reasonably relates to the taxpayer’s net interest and financing expense). ...

PWC, "Tax Insights: Excessive interest and financing expenses limitation (EIFEL) regime", Issue 2022-06, 15 February 2022-- summary under Acceptable Accounting Standards Summary Under Tax Topics- Income Tax Act- Section 18.21- Subsection 18.21(1)- Acceptable Accounting Standards Non-recognition of local European GAAP The group ratio rule in draft s. 18.21, which may enable taxpayers to access a higher fixed percentage than 30% where the group as a whole is bearing higher interest and financing expenses as a result of its external debt and as measured by the group GAAP financial statements, does not recognize any local European GAAP – so that the group ratio calculations could be unavailable for European-headed groups that do not consolidate using IFRS. ...

Joint Committee, "Reportable Transaction and Notifiable Transaction Proposals", 5 April 2022 Joint Committee Submission-- summary under Avoidance Transaction Summary Under Tax Topics- Income Tax Act- Section 237.3- Subsection 237.3(1)- Avoidance Transaction Expansion of “avoidance transaction” (pp. 8-10) The change of the “avoidance transaction” test to refer to “one of the main purposes” of the transaction or series (rather than using a “primarily” test for a transaction) means that, for example, having a small safe income dividend (representing an acceptable tax benefit) as part of a series would render all transactions in the series avoidance transactions – so that the presence of only one hallmark would engage a reporting requirement. ...

EY, "Revised EIFEL proposals", Tax Alert 2022 No. 43, 10 November 2022-- summary under Clause 95(2)(f.11)(ii)(D) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(f.11)- Subparagraph 95(2)(f.11)(ii)- Clause 95(2)(f.11)(ii)(D) No carryforward (pp. 4-5) Per s. 95(2)(f.11)(ii)(D), where a portion of a taxpayer’s IFE for a taxation year is denied under s. 18.2(2), the same proportion of a CFA’s relevant affiliate IFE is similarly denied for purposes of computing its FAPI for the relevant taxation year – but, unlike the treatment of restricted IFE (which may be carried forward to a subsequent year depending on the availability of excess capacity), the denied deduction for purposes of computing FAPI of a foreign affiliate apparently cannot be carried forward. ...

EY, "Revised EIFEL proposals", Tax Alert 2022 No. 43, 10 November 2022-- summary under Subsection 18.2(4) Summary Under Tax Topics- Income Tax Act- Section 18.2- Subsection 18.2(4) Transferee can have a different functional currency or be a REIT (p. 7) The EIFEL revisions have removed the requirement that cumulative unused excess capacity could only be transferred between eligible group corporations that have the same functional currency – and transfers of capacity respecting a “fixed interest commercial trusts” (e.g., most REITS) can now be made. ...